John Warner, Shareholder in the firm’s Tax section, was quoted in “Will Border-Adjusted Tax Halt Inversions? Some Are Skeptical” in Bloomberg BNA’s Transfer Pricing Report on February 24.
John Warner, a shareholder at Buchanan Ingersoll & Rooney PC in Washington, said the “Holy Grail” of tax planning under the new plan would be to receive the U.S. exemption for revenue from foreign sales while shifting costs that aren't deductible in the U.S. to jurisdictions where they are.
“It probably is true that proponents of the border adjustment tax have oversold it as the be-all and end-all to stop the scourge of corporate inversions,” Warner said in an e-mail to Bloomberg BNA. “Multinational groups are constantly seeking to reduce their overall effective rate of worldwide tax, and creative tax advisors will no doubt find ways to allow their clients to have their cake and eat it too.”
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