Possible Obama Anti-Inversion Action More Immediate Threat: ISI
2014-08-08 18:22:09.163 GMT
By Rachel Layne
Aug. 8 (Bloomberg) -- IRS, U.S. Treasury may issue
“unilateral reinterpretation” of inversions-related laws, a
move riskier than conventional rulemaking, ISI analysts Krishna
Guha, Terry Haines and Ernie Tedeschi write in note.
* Treasury’s short-term intent, possibly by the end of
Congressional recess given President Obama’s call for speed
this week, “is to have IRS create as much uncertainty as
possible” around tax provisions so companies “seriously
reconsider whether to invert at all”
* Approach riskier than Treasury action via rulemaking,
which would be viewed as weak by Democrats and take a
year to finalize becuase it opens Obama admin. to
lawsuits
* Congress still unlikely to pass any legislation in 2014
* In 2015, ISI sees successful bipartisan comprehensive tax
reform effort for legislation includling lower corporate top
rate, and movement towards a territorial tax system
* Meanwhile, Democrats most likely to address inversions
via amendments in govt. spending bills this fall, keep
alive anti-inversion “drumbeat by all available means”
in August as a matter of “economic patriotism”
* Republicans still opposed to anti-inversions
legislation, preferring to use issue tax reform driver
in 2015 fall government spending bills
* NOTE: Earlier, Barclays says AbbVie-Shire Still Offers Tax
Savings w/o Inversion; July 29, Bloomberg Intelligence says
AbbVie’s Bid For Shire Tops All Pending Tax Inversion Deals
** Aug. 7, DealRep says bankers evaluate CVRs as tax inversion
hedge; M&A breakup risk evaluated on potential tax legislation
** Aug. 6, Walgreens says Boots deal doesn’t meet inversion
rules
* NOTE: Earlier, Cos. bulk up tax lobbying as Obama seeks to
curb inversions
For Related News and Information:
First Word scrolling panel: FIRST<GO>
First Word newswire: NH BFW<GO>
--With assistance from Cristin Flanagan in New York.
To contact the reporter on this story:
Rachel Layne in Boston at +1-617-210-4634 or
rlayne@bloomberg.net
To contact the editor responsible for this story:
Brad Skillman at +1-212-617-2763 or
bskillman1@bloomberg.net
2014-08-08 18:22:09.163 GMT
By Rachel Layne
Aug. 8 (Bloomberg) -- IRS, U.S. Treasury may issue
“unilateral reinterpretation” of inversions-related laws, a
move riskier than conventional rulemaking, ISI analysts Krishna
Guha, Terry Haines and Ernie Tedeschi write in note.
* Treasury’s short-term intent, possibly by the end of
Congressional recess given President Obama’s call for speed
this week, “is to have IRS create as much uncertainty as
possible” around tax provisions so companies “seriously
reconsider whether to invert at all”
* Approach riskier than Treasury action via rulemaking,
which would be viewed as weak by Democrats and take a
year to finalize becuase it opens Obama admin. to
lawsuits
* Congress still unlikely to pass any legislation in 2014
* In 2015, ISI sees successful bipartisan comprehensive tax
reform effort for legislation includling lower corporate top
rate, and movement towards a territorial tax system
* Meanwhile, Democrats most likely to address inversions
via amendments in govt. spending bills this fall, keep
alive anti-inversion “drumbeat by all available means”
in August as a matter of “economic patriotism”
* Republicans still opposed to anti-inversions
legislation, preferring to use issue tax reform driver
in 2015 fall government spending bills
* NOTE: Earlier, Barclays says AbbVie-Shire Still Offers Tax
Savings w/o Inversion; July 29, Bloomberg Intelligence says
AbbVie’s Bid For Shire Tops All Pending Tax Inversion Deals
** Aug. 7, DealRep says bankers evaluate CVRs as tax inversion
hedge; M&A breakup risk evaluated on potential tax legislation
** Aug. 6, Walgreens says Boots deal doesn’t meet inversion
rules
* NOTE: Earlier, Cos. bulk up tax lobbying as Obama seeks to
curb inversions
For Related News and Information:
First Word scrolling panel: FIRST<GO>
First Word newswire: NH BFW<GO>
--With assistance from Cristin Flanagan in New York.
To contact the reporter on this story:
Rachel Layne in Boston at +1-617-210-4634 or
rlayne@bloomberg.net
To contact the editor responsible for this story:
Brad Skillman at +1-212-617-2763 or
bskillman1@bloomberg.net