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June 06, 2014
“The substantial business activities test requires a concentration of foreign activity in a single foreign jurisdiction that is not consistent with the structure of most multinational corporate groups.”
- Linda Z. Swartz, Chair of the Tax group at Cadwalader, commenting in CQ Roll Call on the proposed Levin Bill’s treatment of an inverted company as a U.S. corporation if at least 25% of the foreign group’s employees, sales or assets are located in the United States, which would potentially discourage foreign companies from investing in the U.S. and could drive domestic subsidiaries of foreign corporations out of the United States.
