The Discreet Charm of the Inversion Rules

8 September 2014
Tax Notes
This report is based on a paper delivered at the New York City Tax Club in April. In this report, Friedman discusses the overreaching nature of sections 7874 and 4985. Those statutes, and the regulatory regimes they have spawned, add complexity and confusion to the tax system, elevate form over substance, and often lead to arbitrary results.