Caroline Ceriello, J.D. Candidate 2017, Columbia Law School With its remarkably low corporate tax rate of 12.5%, Ireland has become home to many companies formerly headquartered in the United States and seeking refuge from the 35% U.S. tax rate. In this context, a “tax inversion” usually refers to a corporate restructuring in which a U.S. corporation is acquired by a foreign holding company and assumes its foreign headquarters as a subsidiary. However, the entity remains listed under the U.S. issuer’s name in U.S. securities markets. As Professor Eric Talley emphasizes, there are three key unique features of the U.S. tax […]
Tax Residency
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