Search Results for ‘inversions’

Obama administration swats inversions, Pfizer deal collapses

After relatively cautious regulatory tightening on corporate inversions failed to deter a plan by Pfizer to embrace foreign domicile, the Obama administration came out with drastic new guidance that will keep accountants and lawyers busy for years with new disputes and uncertainties. Tax law is supposed to be relatively stable, predictable, and reliable for purposes of letting enterprises plan rationally, but that’s when political considerations don’t come first [Paul Caron, TaxProf citing Victor Fleischer, NYT and other links; earlier on inversions including Burger King episode] The underlying arrogance of U.S. overseas corporate tax policy: “We are unique among advanced nations in claiming taxes on global profits” [Hodak Value] Why corporate inversion makes moral sense and promotes healthy tax competition between jurisdictions [Daniel Mitchell, Cato and in January at Fortune]

Related: voters who believe in rule by executive fiat have so many choices this year, Bernie Sanders high among them [@joshgreenman on Twitter]

November 22 roundup

Banking and finance roundup

Banking and finance roundup

Tax flight: King seeks protection of Queen

CanadaQueenStampRemember when Canada was regarded as the high-tax, big-government country, and we weren’t? How times have changed. Burger King is considering becoming Canadian through a tax inversion deal with donut chain Tim Horton’s, aware that north of the border “corporate tax rates are as much as 15 percentage points lower than in the United States,” in the words of Daniel Ikenson at Cato, who writes: “If the acquisition comes to fruition and ultimately involves a corporate ‘inversion,’ consider it not a problem, but a symptom of a problem. The real problem is that U.S. policymakers inadequately grasp BurgerStamp that we live in a globalized economy, where capital is mobile and products and services can be produced and delivered almost anywhere in the world, and where value is created by efficiently combining inputs and processes from multiple countries. Globalization means that public policies are on trial and that policymakers have to get off their duffs and compete with most every other country in the world to attract investment, which flows to the jurisdictions where it is most productive and, crucially, most welcome to be put to productive use.” And the fact is that the United States, once the domicile of choice for international business, has slipped badly down the ratings of how difficult it is to do business in various countries. Policymakers “should repair the incentives that drive capital away from the United States.” Full post here. More: Stephen Bainbridge.

Banking and finance roundup

Coaching police experts

Lawrence Taylor at DUIblog (Mar. 17, via Cernovich) has got the goods on a coaching memo given by the San Diego Police Department to the technical experts they put on the stand to testify as to drivers’ blood-alcohol levels (emphasis in original memo):

You will always mix any tube with an anticoagulent [sic] 10 times (you count the inversions). The important things to remember is that you always follow the same procedure, so even though you don’t remember this particular individual, you know that you drew the person following our standard procedure.

As Taylor observes, the witnesses are instructed to testify under oath to an account calculated to help the prosecution prevail, “not as to what they actually did and what they know to be true in a specific case”.

For more on witness-coaching, see Sept. 10, 1999, Sept. 22-24, 2000, and, of course, our many entries on the famous Baron & Budd witness memo scandal.