From Dublin to Delaware: Exploring the Factors Driving the Inbound Question

Have recent changes to the U.S. and global tax landscape made the U.S. is a more attractive headquarters jurisdiction or are non-tax factors driving the conversation?

Favorable U.S. tax changes enacted in OB3 and the recently announced Pillar Two Side-by-Side system have precipitated C-suites of foreign multinationals to consider whether inbounding into the United States could make sense. Is the United States now a more attractive tax jurisdiction relative to foreign jurisdictions, or has the playing field merely been leveled? What non-tax factors could play a decisive role in the decision-making process? What are the potential impediments to, and costs of, inbounding? Is the U.S. tax system a “lobster pot” that companies really want to enter?

Join us as our hosts Gary Scanlon and Kristen Gamboa interview Gordon Warnke, Principal in charge of the Complex Transactions Group and Co-Principal in charge of the WNT M&A Tax practice, and Stephen Massed, a principal in the same group, to answer these questions and more on the latest episode of Inside International Tax.