IRS to Focus on Offshore Earnings in 2017 Audits

Last week, federal law enforcement officials executed a high profile raid of Caterpillar to investigate accusations of international tax fraud. Regardless of the merits of the case against Caterpillar, the raid may have been meant to send a broader message to multinational companies that the United States will scrutinize strategies to shift income to lower


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,