AbbVie's Reversal Reflects Uncertainty Over Future Inversion Rules

Tax Notes Today, Worldwide Tax Daily
October 17, 2014

Douglas S. Stransky was quoted in an article entitled "AbbVie's Reversal Reflects Uncertainty Over Future Inversion Rules," published on October 17, 2014 in Tax Analysts’ Tax Notes Today and Worldwide Tax Daily. The article discusses the decision by AbbVie Inc.'s board of directors to reverse its previous recommendation that shareholders back a proposed merger with Shire PLC in light of the recent guidance from the U.S. Treasury on inversions under Internal Revenue Code section 7874.

Mr. Stransky comments "that because tax is just one of many factors that companies consider when contemplating inversions, AbbVie may not signal a trend in collapsed deals. But companies will look hard at whether the math will work for them. More important, they will look hard at what other unilateral actions the U.S. government might take to stop a transaction it does not like because of some perceived abuse. It's that uncertainty that's likely to stop more transactions." 

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