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David Rosenbloom Speaks to Bloomberg Law on "AbbVie Moves Allergan Profits to U.S. in Partial GOP Tax Law Win"

June 26, 2019, Bloomberg Law

AbbVie Moves Allergan Profits to U.S. in Partial GOP Tax Law Win

Allergan Plc, the drugmaker that emigrated to Ireland to avoid U.S. taxes in 2015, is now coming home—at least partially.

Allergan’s income will generate some U.S. taxes because of a deal announced June 25 for AbbVie Inc. to acquire the Dublin-based company, even though it will remain in Ireland.

Even the partial homecoming represents a win for U.S. lawmakers and regulators who have spent years trying to stop companies from moving their headquarters abroad to largely avoid taxes.

. . . . .

But even paying taxes to foreign countries, such as Ireland, and some GILTI tax to the U.S., companies can end up with lower overall tax bills than if they fully operated in the U.S., said H. David Rosenbloom, an international tax lawyer at law firm Caplin & Drysdale and a former Treasury official. GILTI is an “incentive” for companies to “chase foreign assets,” he said.

Read the full article at Bloomberg Law.


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