Tax Reform Proposal Unveiled

Today the White House outlined its proposal for tax reform and rate reduction. Unveiling the plan, White House Chief Economic Adviser Gary Cohn touted the plan as one of the greatest tax reductions in United States history. The White House plan would slash tax rates for businesses to 15% from as high as 35%, and

How Corporate Inversions Give Foreign Acquirors a Comparative Advantage

The current US corporate tax regime has created an unintended incentive for corporations founded in the US to redomicile overseas—a so-called corporate inversion.    To make matters worse from a US perspective, the current corporate inversion rules effectively give foreign acquirers a pricing advantage over US corporations who are potential acquirers. As we have previously explained,

Corporate Development Strategies in 2016

As we enter into the new year, McCullough Sudan is pleased to launch of its new blog: “Corporate Development Strategies” (www.corp-dev.com). This blog will examine the legal, business and tax aspects of corporate development including mergers, acquisitions, joint ventures, expanding into new foreign and domestic markets, and the development and commercialization of technologies. We will

Latest Corporate Inversion: Johnson Controls and TYCO

According to New York Times’s Dealbook, Johnson Controls has agreed to merge with Tyco to redomicile from the United States to Ireland and thereby reduce its global tax bill. Corporate inversions have been in the IRS’s cross-hairs for some time. Recently, in November 2015, Treasury announced new rules intended to make corporate inversions more difficult.