The US Tax Cuts & Jobs Act (TCJA) is failing to prevent inversions, with the lure of foreign capital often outweighing the tax challenges for rapidly expanding businesses.
Inversion considerations for businesses
The lower post-TCJA rate is an incentive to remain headquartered in the US, but also less of a disincentive to leave.
Another consideration for emerging businesses and their Asian investors is GILTI. "The imposition of GILTI would be of particular concern to a Chinese company holding investment in a US Company .This is quite common," said Anthony Tam, a tax partner at Mazars Hong Kong.
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Credits: Danish Mehboob for International Tax Review, 1 April 2019