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May 19, 2014
Linda Z. Swartz, Chair of the Tax group at Cadwalader, spoke to the Financial News regarding the current statute that governs the structuring of inversion transactions as well as the three primary drivers that typically motivate the choice of foreign jurisdiction for a U.S. company seeking to invert:
“The statute that governs inversions is full of bright lines and the IRS commissioner has quite properly observed that transactions structured within the bright lines can qualify as effective inversions.” Some of the leading jurisdictions targeted in these deals are Ireland, which has historically been a top choice, as well as the UK and the Netherlands, Swartz said. She added: “Three drivers that we have seen garner a lot of attention are the governance rules, the tax regimes and the treaty networks of foreign jurisdictions, and a combination of those drivers typically determines the foreign jurisdiction of choice.”
