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Thursday, July 26, 2012

Wells: Section 7874 Has Not Stopped Corporate Inversions

Tax AnalystsBret Wells (Houston), Cant and the Inconvenient Truth About Corporate Inversions, 136 Tax Notes 429 (July 23, 2012):

Wells writes that inversion transactions and inversion benefits are still available and are being pursued even with the enactment of § 7874. That section obscures the fundamental design flaws of the tax system without solving the underlying defects. The inversion transactions that have occurred since the enactment of § 7874 prove that Congress should reform the U.S. international tax regime.

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Comments

Cant? Is that "Kant" misspelled, or did I miss something?

Posted by: anon | Jul 26, 2012 4:33:08 PM

Responding to "anon": Footnote 59 of the article reads, in part: . . . see also Commissioner v. Newman, 159 F.2d 848, 850-851 (2d Cir. 1947) (L. Hand,J., dissenting) (‘‘Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.’’).

Elsewhere, the word "cant" has been defined as monotonous talk filled with platitudes and hypocritcially pious language.

Posted by: TexEcon | Jul 27, 2012 8:07:09 AM

Marvelous! Thank you.

Posted by: anon | Jul 27, 2012 8:14:05 PM