Over half of the 76 U.S. companies that have used international mergers to escape American taxes in the last three decades have done so since the recession, according to a list from the Congressional Research Service (CRS).
The list tracks a type of merger known as an “inversion,” in which a company located in one country acquires one based abroad and then deems the other, lower-tax country as the home for the headquarters of the merged corporation. The first inversion the CRS found was in 1983, and 11 years passed before the second took place. But since 2008, 42 different companies have inverted, according to the researchers, and another 11 companies are weighing an inversion in the near future.
Moving companies offshore for tax purposes has attracted significant scrutiny in the past year or so, with corporate executives from Apple, Caterpillar, and other well-known companies being hauled before Congress to explain how their international accounting schemes are legal. Pfizer recently failed to acquire the British drugmaker Astra Zeneca in a deal that would have both created the world’s largest drug company and allowed Pfizer to shave billions off of its U.S. tax bill. Corporate offshoring of profits costs the Treasury Department between $30 billion and $90 billion per year, according to previous CRS research. A total of $2 trillion in U.S. corporate profits is now being stockpiled abroad.
The list of tax inversion deals, published this month by the Democrats on the House Ways and Means Committee, illustrates how the practice of corporate inversions has accelerated since the financial crisis. Deals like these allow an American company to relocate its tax base without necessarily shifting any of its actual production, sales, research, or other business capacity out of the country. The deals are carefully structured to adhere to the letter of the international corporate tax system and they do not generally violate U.S. tax laws. But they allow companies to hide revenue that would otherwise be subject to U.S. taxes in countries like Ireland, Luxembourg, Switzerland, or the Bahamas that have very generous corporate tax laws designed to lure corporate money.
The amount of business income that American companies report as coming from such “tax preferred countries” is “disproportionate to the location of the firm’s business activity as indicated by where they hire workers and make investments,” a separate CRS report from 2013 found. Bermuda, Ireland, Luxembourg, the Netherlands, and Switzerland were home to a combined 43 percent of U.S. corporate overseas profit in 2008 despite hosting just 4 percent of overseas hiring and 7 percent of total foreign investments by those companies, the report noted.
As corporations have gotten bolder about depriving the U.S. of tax revenue, workers have been left holding the bag. While corporate income tax collections made up almost a third of all federal revenue at one point in the 1950s, they now supply less than 10 percent of all tax payments. Payroll taxes — half of them paid directly by workers, the other half paid by employers who might otherwise spend that money on salary or benefits — have had to make up the difference. Collections from workers have gone from about 10 percent of all tax revenue to roughly 40 percent over the same time frame that corporate collections collapsed.