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).
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)
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.
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:
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)Reply
