Document Type
Article
Publication Date
2015
Abstract
The recent announcement that Pfizer Inc. has reached a merger agreement with Allergan PLC, with the combined entity being tax resident in Ireland, is a good occasion to reconsider U.S. policy options in regard to inversions. We consider an "inversion" as any transaction in which a U.S. corporation becomes foreign for tax purposes without a meaningful change to its underlying business or management activities. This short article explains what we believe to be the true motives of inversion transactions, as well as potential policy responses, in light ofthe Pfizer inversion. Part II explains what is unique about the Pfizer inversion so as to make it a case study worthy of special consideration. We use the Pfizer deal to reject the argument that inversions are driven by "competitiveness" considerations.
Recommended Citation
Avi-Yonah, Reuven S. and Omri Y. Marian. "Inversions and Competitiveness: Reflections in the Wake of Pfizer-Allergan." International Tax Journal 41, no. 6 (2015): 39-46.
Comments
© 2015 R. S. Avi-Yonah. This article is reprinted with the publisher’s permission from International Tax Journal, a bimonthly journal published by CCH Incorporated. Copying or distribution without the publisher’s permission is prohibited.