Red Light, Green Book: The Anti-Inversion Proposals

Inside International Tax, Episode 08-2021 | How would the Biden administration tax framework affect foreign takeovers of domestic businesses?

Gary Scanlon

Gary Scanlon

Principal, International Tax, Washington National Tax, KPMG US

Stephen M. Massed

Stephen M. Massed

Principal, International Tax and M&A Tax, Washington National Tax, KPMG US

+1 202-533-4738

Andrew D. Simmons

Andrew D. Simmons

Managing Director, Corporate, Washington National Tax, KPMG US


Podcast overview

Part 3 of our series on the Biden administration’s tax proposals wraps up discussion of the Green Book with a look at the provisions aimed at shutting down tax-motivated inversions of U.S. businesses. This effort to clamp down on inversions has been going on for a number of years, playing out in the headlines of major news publications, with the sticks and carrots of the TCJA representing the most recent salvo.

The anti-inversion proposals in the Green Book would raise the barriers to exit even further. This podcast describes changes proposed by the Green Book and discusses some of the implications for acquisitive companies. What ownership thresholds trigger these rules, and should foreign companies that are “managed and controlled” in the United States be concerned? How might the new partnership rules affect the private equity industry?

Our host Gary Scanlon interviews KPMG Washington National Tax professionals Steve Massed and Andrew Simmons about the Green Book tax plans and their impact on acquisitions of domestic corporations. 

Listen to Part 1, Greener on the Other Side? The Inbound Perspective of the Green Book

Listen to Part 2, Green Green Grass of Home: The Outbound Perspective of the Green Book

More KPMG Inside International Tax podcast episodes