Bill introduced in Senate to tighten anti-inversion rules

Senator Bob Casey (D-PA) has introduced an amendment to the anti-inversion rules under Code Sec. 7874, as part of efforts to fund universal pre-kindergarten programs. His proposal would reduce the applicable threshold used to treat a foreign corporation as a domestic corporation from “at least 80%” to “more than 50%,” “so that companies would need to be at least 50 percent foreign-owned (as opposed to just 20 percent) to escape U.S. tax jurisdiction.”