Talk:Tax inversion/Archive 1

Archive 1

Don't delete me

Corporate Inversion is a term of art for when corporations move their headquarters to a foreign country as a tax dodge.

Numerous legal and government articles use this term of art in their titles.

It is appropriate to define an article around this term of art to serve as a reference to the articles that are written around this subject. Doing so goes beyond the function of a dictionary and serves also to tie together other articles in Wikipedia related to this subject.

Erxnmedia (talk) 14:29, 8 October 2008 (UTC)

Might this be better served by creating a section under tax avoidance or tax haven and redirecting the "Corporate Inversion" article to those pages. The material appears important to mention, the question is if it should receive an article of it's own at this point, or be included in another article until it grows to sufficient length to merit its own article. If there are plans to greatly expand this article, than it may merit its own article if it is notable enough. Morphh ^(talk) 14:39, 08 October 2008 (UTC)

Agree with Morphh. This is essentially a dictionary term that can be covered off within tax avoidance, tax haven or corporate haven articles. I know it was speedied on the basis that it looked like a dictionary definition, but I am also worried by the sourcing. One anyone-can-edit encyclopedia should not rely upon another anyone-can-edit source as its primary basis. Speaking as a practitioner in this area, it must be a US-centric term, as it is not a term that I am familiar with (although it seems to render a sufficient number of Google hits to appear genuine). --Legis (talk - contribs) 16:22, 8 October 2008 (UTC)

I agree that it is a US-centric technical term. It is the term used by the IRS, in one of the many links I provided. There is otherwise no Wikipedia article that defines this term. I go to Wikipedia to learn about concepts that I don't otherwise know, so I think it should be here.

I agree that articles on Tax haven and Corporate haven and Tax avoidance and tax evasion could be merged or organized better. If you wanted to roll up 4 articles into one mega article that might be a solution, although there is also a suggested size limit on Wikipedia articles (less than 100kbytes roughtly).

Erxnmedia (talk) 19:31, 8 October 2008 (UTC)

Not US invention

Let's not be US centric please. The process of re-incorporating in a lower tax haven jurisdiction is nothing new. There are ample example from colonial times from colonizing nations where companies moved headquarters to new territories to gain tax advantages.207.87.238.194 (talk) 12:46, 27 August 2014 (UTC)

Not quite sure what you are advocating, but I would just add the comment that, in my own view, the terms 'tax inversion' has become much more globalised (and much more topical) since the last exchange on this talk page back in 2008 (above). If anyone is asking, my own view is that this subject certainly deserves its own page at this time, and has been developing nicely recently. I am still a little fuzzy on where the term originated from, but if anyone has a source, then please plug it in. --Legis (talk - contribs) 19:48, 27 August 2014 (UTC)

Re-write for 2018

giving this article an upgrade since the developments to 2018 (incl. TCJA) and also re-written summary to remove bias etc. (have not touched the Mechanics section which still could be biased so moved the marker down to it) Britishfinance (talk) 15:54, 16 April 2018 (UTC)

I've moved most of the text from the lead into an overview section. That should help with the lead length and other issues. We can add some more info back to the lead but it should be summarized at a high level and as simple as we can make it.Farcaster (talk) 20:57, 19 June 2018 (UTC)

Re-write for 2019

This article is not right (per the tags) and is partly my fault as I tried to tack on a partial 2018 re-write to existing older material. Both my 2018 re-write (I was a poorer WP editor back then), and the older material were also not great content with variable sourcing. I am almost completed a full re-write of this article (currently in my sandbox). I have much better souring (main 2017 to 2019 reports on tax inversions), and I have a properly integrated article. I plan to complete in the next few days and will past into this in place of the old material. I have been able to use about 30% of the existing references in this article (especially ones that are less than 5 years old and are from high-quality sources), and am mindful of retaining anything of value. However, given that the article needed a complete re-write/re-structure, it will look very different. Hopefully, it will be appreciated. Britishfinance (talk) 17:20, 15 April 2019 (UTC)

Actually, I have been able to incorporate almost 60% of the current refs, however, the rest are just too old, or are involved with redundant material. Britishfinance (talk) 21:33, 15 April 2019 (UTC)

I think you've done an amazing job! I would ask that you re-introduce near the opening a very simplified explanation much like this one in a prior version, from this article. "Journalist Matt Levine described how an inversion works in Bloomberg during August, 2014. U.S. companies pay a tax rate of 35% on income they earn in the U.S. and abroad, but they obtain a credit against their U.S. tax liability for the amount of foreign tax paid. This is referred to as a "worldwide approach" as opposed to the territorial system used by most other developed countries. Levine explained: "If we're incorporated in the U.S., we'll pay 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we're incorporated in Canada, we'll pay 35 percent on our income in the U.S. but 15 percent in Canada and 30 percent in Mexico and 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands." By changing its headquarters to another country with a territorial tax regime, the corporation typically pays taxes on its earnings in each of those countries at the specific rates of each country. Further, the corporation executing the tax inversion may find additional tax avoidance strategies allowed to corporations domiciled in foreign countries not available in the U.S. For example, the corporation may find ways of defining its revenue or costs such that they are taxed in lower-tax countries, although the customers may be in higher-tax countries.[18]Bloomberg — Preceding unsigned comment added by Farcaster (talk • contribs) 13:36, 21 May 2019 (UTC)

@Farcaster: I have made that change now with a few edits; I hope this is what you were thinking of? thanks. Britishfinance (talk) 10:02, 29 May 2019 (UTC)

Very helpful, thanks!Farcaster (talk) 12:19, 29 May 2019 (UTC)

@Farcaster: great and thanks; also take a look at the related tax haven article which I have updated a lot to proper academic sourcing and core academic teaching; it had been degraded a lot in my view by editors using poorer RS (e.g. too much NGO material), and even by editors advocating on behalf of their home countries (e.g. references to major countries as tax havens being taken out, and material deleted). Like tax inversions, the subject is now sufficiently well researched to write stable encyclopedic articles. Britishfinance (talk) 13:01, 29 May 2019 (UTC)

GA Review

This review is transcluded from Talk:Tax inversion/GA1. The edit link for this section can be used to add comments to the review.

Reviewer: Goldsztajn (talk · contribs) 07:57, 7 May 2020 (UTC)

Parking this here for the review. --Goldsztajn (talk) 07:57, 7 May 2020 (UTC)

Rate	Attribute	Review Comment
1. Well-written:
	1a. the prose is clear, concise, and understandable to an appropriately broad audience; spelling and grammar are correct.	Some cases where more summaries would be helpful (see below)
	1b. it complies with the Manual of Style guidelines for lead sections, layout, words to watch, fiction, and list incorporation.	Problems with list incorporation (at least 70 bulleted points in the article, see below). Structure of the article needs better logic (see below) Citations need clean up (see below) Lead contains too much detail and needs to more explicitly indicate the consequences of tax inversion (ie minimisation of corporate global tax liabilities *and* net decreases in global public tax collection).
2. Verifiable with no original research:
	2a. it contains a list of all references (sources of information), presented in accordance with the layout style guideline.	This is basically a pass at this level, but IMO it is right on the borderline. I see the following problems: Due to the mixture of footnote sytles I find following the footnotes quite complicated. The entire article should be converted to a short footnote style {{sfn}} and the reference section grouped accordingly. I would suggest reference groupings as follows around Notes, Footnotes, Works Cited. Many cases of over referencing (some examples: Hybrid inversions, second paragraph: two sentences, eight citations with six separate references / Countermeasures UK: four sentences, four citations to the same reference)
	2b. reliable sources are cited inline. All content that could reasonably be challenged, except for plot summaries and that which summarizes cited content elsewhere in the article, must be cited no later than the end of the paragraph (or line if the content is not in prose).	Although not affecting the GA assessment, there is a preponderance of sourcing to US government publications, I would recommend some balancing with peer-review publications and/or to some of the multilateral organisations that publish on this topic (eg OECD, IMF). The Marples & Gravelle citation does not seem to be working correctly (see footnotes 96 and 101, something related to the fact that there are two different publications to the same authors)
	2c. it contains no original research.
	2d. it contains no copyright violations or plagiarism.	Earwig shows an unlikely result, but making comparisons here and here, there are two examples of extremely close paraphrasing. I checked ten other references and these seem fine, but would suggest a detailed check before any resubmission.
3. Broad in its coverage:
	3a. it addresses the main aspects of the topic.	Some issues that are left out (or which I missed): defence of the practice (eg Towarnicky (2015)), those who argue the problem cannot be solved due to political interia (Fuller and Thomas (2017)), inversion leads to declines in employment in the US (Rao 2015), experience from outside UK/USA (Col, Liao and Zeume (2016) present evidence which includes Australia, France, Germany and others). Finally I think the nature of how this is a deeply political issue could be more explicitly discussed - the ways in which the Obama administration watered down its own regulations or that the TCJA has loop holes are just two examples of many that illustrate the nature of the problem.
	3b. it stays focused on the topic without going into unnecessary detail (see summary style).	I think the structure of the article is part of the problem here, since there are multiple sections which tend to produce far too much detail on the minutiae of tax inversion, while, in particular, not making explicit the broader political debate around the issue. I would suggest a structure as follows: 1. Definition 2. Historic origins 3. Notable examples (no more than three - Apple would be obvious given the consequences, Pfizer possibly as it was blocked...) 4. Policy debate (role of key players; corporations, governments, social movements, OECD BEPS process, unitary tax debate) 5. Current trends. The industries section seems a little bit of a sideline – it starts implicitly by saying around 2/3 are not from those sectors ... so why is discussion of 40% necessary? Earning strippings should be part of definition. Costs would be part of policy debates. Countermeasures could be significantly shortened and incorporated into policy debates. There is a significant overuse of bullet points to provide examples. These generally all contain too much descriptive detail which do not assist with clarity, but rather cause a general reader to get lost. Some examples: Notable Inversions lists 20% of all US inversions, but there is no indication why any of these are actually more notable than the other 80% not listed. I think there are a number of points where there is too much focus on issues which are related to tax avoidance/minimisation in general, rather than the specific case of tax inversion, and these could be dropped. The Hybrid inversions section is a case in point. BEPS has many forms, one of which is tax inversion. Calling this section hybrid inversion seems to me to border on SYNTH. What is called IP inversion is a case in point. This is a general practice that is carried out irrespective of corporate tax inversion and been going for a long time: Nestlé's acquisition of Rowntree in 1988 saw the brands shifted to Switzerland (I believe this was one of the first cases in Europe). As an aside, the term IP Inversion itself seems quite US centric, intangibile assets seems to be used more in the European context.
	4. Neutral: it represents viewpoints fairly and without editorial bias, giving due weight to each.
	5. Stable: it does not change significantly from day to day because of an ongoing edit war or content dispute.
6. Illustrated, if possible, by media such as images, video, or audio:
	6a. media are tagged with their copyright statuses, and valid non-free use rationales are provided for non-free content.	On Commons File:OECD_countries_with_worldwide_tax_systems.png has the author as "Own work", however it is a Tax Foundation image. Same problem with File:OECD 2018 Corporate Tax Rates.png, also Tax Foundation image.
	6b. media are relevant to the topic, and have suitable captions.	Comments on images: 2018 headline corporate tax rates – This table seems to me to be wrong. First the data is 2017, not 2018. Second, US is placed at the top, whereas France has a higher statutory rate than the US. I think it would be better to refer to the OECD data directly here: [1]. OECD "worldwide tax" countries – The significant issue in this picture does not seem to be incorporated into the text, that is, for 100 years (1891-1991) only 7 or 8 countries changed their status, but then in the space of 20 years, 1991-2011, 19 countries changed their status. What happened in those last 20 years? I would suggest this picture would actually be more useful in a origins/history section. Also, in the footnotes, this graph should also be cited to original source at the Tax Foundation and not to Wharton. "The legal headquarters of Medtronic in Dublin, Ireland" – It is not clear what is being illustrated here; is it the building on the corner? It looks like the building on the corner is named something other than Medtronic – this in itself would be useful to point out if correct. Major phases of US corporate tax inversions – worthwhile noting in the caption that this illustrates the acceleration since 2002. Annual number of US corporate tax inversions (1983–2016) – sourcing text should be removed from this image. Assets of completed and aborted US inversions – not clear what significance this illustration seeks to highlight. The material fall in the US aggregate "effective" corporate tax rate – not clear what is the purpose of this illustration; it illustrates that at the same time as US effective corporate tax rates have declined, corporate profits and tax receipts have grown. This is precisely what the boosters of tax liberalisation argue for – is this being presented as evidence to support arguments towards that end? Whether there is a correlation is not clear in any case.
	7. Overall assessment.	This is an important article and certainly one which has significant contemporary interest, notability and relevance. It is definitely a worthwhile effort in bringing this to good article status. There is also no lack of information contained within the article and the work bringing it to this level should be acknowledged. Unfortunately, there are significant issues related to GA criteria and in the present form there is too much work for it to be placed on hold – I would recommend a significant round of editing and resubmission. The key areas which need focus are summary of issues, clarity over what is specifically notable, improvement in the use of graphics as related to text, improved structure and cleaning up sourcing. --Goldsztajn (talk) 18:19, 9 May 2020 (UTC)