As more and more American companies have used international mergers to move their profits out of U.S. tax jurisdiction, the Wall Street firms that encourage and facilitate the deals have raked in close to a billion dollars in fees. The top 10 firms to work on the so-called “inversion” deals have brought in $819.8 million from the deals in just the past three years, according to a New York Times analysis.
The top of the list of corporate offshoring advisers is full of familiar names. Goldman Sachs leads the way with an estimated $203 million in fees, followed by JP Morgan ($185 million), Morgan Stanley ($98 million), and Citigroup ($72 milion). Those figures represent just the past three years of deals and are based on both public disclosures and analyst estimates of the fees paid in various corporate deals.
The deals in question — called “inversions” because they involve an American company buying a foreign-held firm based in a low-tax country and then flipping the merged company’s address to the tax haven nation without necessarily relocating in any practical sense — have boomed in the years since the recession. But the Times figures only date to 2011, so fees paid to the banks on dozens of inversions in prior years aren’t counted.
The deals are great for banks, and the corporate tax savings from them make Wall Street’s cut of the deal look tiny. But they have come under increasing fire in the past month as the White House has called for “a new sense of economic patriotism” from the country’s business elites and billionaire investor Mark Cuban has promised to sell off his holdings of any company that ditches America in order to shrink its tax bill. A bill to close the loophole that makes inversions legal has been introduced by the House by Rep. Sander Levin (D-MI), and the Joint Committee on Taxation thinks the bill would save taxpayers almost $20 billion over the next decade.
Inversions are just one facet of the many-splendored jewel that is international corporate tax evasion. The eccentricities of the tax code and the international race to the bottom among tax haven countries like Ireland, Luxembourg, Switzerland, and various islands in the Caribbean mean that companies have a variety of options for legally reducing their U.S. tax bill while maintaining their day-to-day operations in America. Apple, Google, Microsoft, Caterpillar, and many other business giants use elaborate licensing deals and shell company subsidiaries to shift profits off their American books.