Saturday, February 20, 2016

"A New Frontier In Tax Planning: Personal Inversions"

From the TaxProf blog:
New York Times:  Just Send the Tax Bill to My Personal Irish Subsidiary, by John Schwartz:
I want to lower my taxes. It’s one of my dreams, along with becoming taller. And younger. And much, much richer.
I can’t do anything about most of that list. I do know one way to pay less to Uncle Sam, but the only surefire method I have ever come up with is to make less money. I’ve been there. Didn’t like it.
So I’ve decided to try something more sophisticated. I’ll invert myself. ... I’d like to borrow a nifty trick from the business world, where it is called a corporate tax inversion.
It works like this: Using merger magic, American companies move their headquarters to a country with lower rates. They escape the high American corporate tax rate, and also our taxation of a company’s worldwide income. (Many other countries tax just profits within their borders.)
The beauty is that a corporation doesn’t actually have to move much of anything, except its supposed tax headquarters: Top executives can stay stateside. ...
I want to act like a corporation and enjoy the good life. How hard could it be?
I called Adam Chodorow, who teaches tax law at the Sandra Day O’Connor College of Law at Arizona State University. Professor Chodorow has expertise in many areas of tax law, with respected scholarship in his field. He also wrote a law review article, Death and Taxes and Zombies, which examined how estate and income tax laws might apply to the undead. This, my friends, is the kind of out-of-the-box thinking I was seeking. ...
He suggested I would be going to a lot of trouble, since I had a way to stop paying United States taxes already....MORE