What about US " little people ?
I Hear America Singing
'Never Pay Taxes':
The Inversion Operetta
By Zachary R. Mider
December 18, 2014 - The only operetta ever written about Subpart F of the
Internal Revenue Code made its debut on a rainy Sunday evening in May 1990,
in a Fifth Avenue apartment overlooking Central Park. In bow ties and spring
blazers, partners of the law firm of Davis Polk & Wardwell dined on lobster
prepared by a Milanese chef. Then everyone gathered around a piano, and a
pair of professional opera singers, joined by the few Davis Polk men who
could carry a tune, performed what sounded like a collaboration of Gilbert &
Sullivan and Ernst & Young.
The 13-minute operetta, Charlie's Lament, told whole category of corporate
tax avoidance and successfully defended it in a fight with the Internal
The lawyers sang:
The Feds may be screaming, But we all are beaming 'Cause we'll never pay
taxes, We'll never pay taxes, Never pay taxes again!
The first corporate "inversion," as Carroll's maneuver came to be known, was
obscure then and is all but forgotten now. Yet at least 45 companies have
followed the lead of Carroll's client, New Orleans-based construction
company McDermott International, and shifted their legal addresses to
low-tax foreign nations. Total corporate savings so far: at least $9.8
billion - money that otherwise would have gone to the U.S. government.
This year, inversions have received more attention than ever, as well-known
companies such as Burger King Worldwide Inc. and Pfizer Inc.
announced plans to change their addresses. (Pfizer didn't follow through.)
In July, President Barack Obama called the practice an "unpatriotic
tax loophole" and urged Congress to put a stop to it. In September , the
U.S. Department of the Treasury tightened regulations to discourage the
deals. "My attitude is, I don't care if it's legal," Obama said in July.
If history is any guide, the stiffer regulations won't stop the exodus. Ever
since the McDermott deal, inversions have been the subject of legions of
congressional hearings, bills, and regulations, yet companies continue to
find ways to circumvent them and escape the U.S. tax system.
John Patrick Carroll, You're the man for me. You have a firm that is
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