John P. Warner, shareholder in Buchanan's Tax section, was quoted extensively in a Bloomberg Law Daily Tax Report article regarding the recommendation that U.S. based companies incorporate offshore at outset to avoid anti-inversion rules.
“Rather than establishing a foreign parent, for instance, a founder could set up a separate foreign entity in a “brother-sister” structure, according to John Warner, a shareholder at Buchanan Ingersoll & Rooney PC in Washington.
“I broach it with startup clients, but almost inevitably they say “Well, you know, let’s get the U.S. enterprise off the ground,’” Warner said. “You do need the perfect storm of confidence, and maybe a bit more money than a startup gets, and sophistication about how significant things can get down the road.”
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