International Business
Geringer, McNett, Minor, Ball
Instructor Guide to Module 8
cost of conducting business in Brazil, known as “Custo Brasil,” was hurting domestic
manufacturing, and incoming foreign investments threatened to overwhelm Brazilian markets.
Under President Dilma Rousseff, economic growth stagnated, and Brazil struggled to find the
best balance between reducing inflation, maintaining a flexible exchange rate, and improving
the competitiveness of Brazilian exports.
CONTROVERSIAL ISSUE
Inversions Still have Their Appeal
The U.S. Treasury restrictions tightened merger rules that went into effect recently, which make
it more difficult for U.S. companies to access their overseas cash unless it is taxed at U.S. rates
and tightens the conditions under which a merger can be an inversion. Inversions were once an
esoteric tax loophole, but in the past few years have come to be used more frequently as a way
to reduce tax rates. Essentially, they allow companies to lower their corporate tax rates by
buying foreign companies. Here’s how it works: the company either sets up or buys another
company in a country with a lower corporate tax rate and then calls the new country home.
Essentially, nothing moves. The company simply moves its legal address outside the U.S. Then
the company can move some of their profits to the new company and lower their tax rates.
U.S. corporate rates tend to be higher than those in many other countries. For example, U.K.
rates are around 20%, while U.S. rates are almost 40%, before tax credits. The average tax rate
in 2010 among the 10 most profitable U.S. companies was 25.4%, according to Forbes
(http://www.forbes.com/2011/04/13/ge-exxon-walmart-apple-business-washington-corporate-
taxes.html). So inversions lower tax rates and yet, the company still operates in the U.S.,
enjoying conditions supported by the taxes of other businesses and individuals.
Despite the Treasury clampdown, U.S. businesses continue to practice inversions as a part of
their corporate tax strategy. There were 14 inversions completed in 2014 and many are
planned as of mid-2015, including Coca Cola Enterprises (a bottler and distributor) and CF
Industries, both to the U.K.
• What is meant by an inversion deal?
• Another way to look at inversions is that they are examples of the benefits of
globalization. Companies are simply exploiting a comparative advantage. Evaluate this
viewpoint.
• A recent The Economist August 15, 2015) article suggests that U.S. tax law is
what has to change and that until it does, U.S. cash-rich companies abroad (who do not
pay U.S. taxes until profits are repatriated) will be targets for acquisition by non-U.S.
companies. Evaluate this perspective.