Regulation and Red Tape: Tax Inversions: Unpacking the Pfizer Case

In 2014, the pharmaceutical company Pfizer initiated a restructuring, only to encounter impediments from the United States Department of the Treasury, further halting any prospective Congressional action. During this period, the United States had among the highest corporate income tax rates in the world, prompting the Department of the Treasury to scrutinize Pfizer’s actions, characterizing them as an attempted tax inversion. The IRS, in the face of a gridlocked Congress, issued a notice of proposed rulemaking that would begin altering regulations, thereby thwarting numerous existing structures, including Pfizer’s proposed transaction, from securing approval.

In episode four of the “Regulation and Red Tape ” series, experts provide an exposition of corporate tax inversions, spotlighting Pfizer’s case, and raise pivotal questions concerning the balance of powers when time-sensitive policy matters are at stake.

Stephanie Hunter McMahon

Professor of Law

University of Cincinnati College of Law

Raymond Wiacek


Jones Day

Hon. Paul Ray

Director, Thomas A. Roe Institute for Economic Policy Studies

The Heritage Foundation

Enforcement & Agency Coercion
Financial Services & Corporate Governance
Regulatory Process

The Federalist Society and Regulatory Transparency Project take no position on particular legal or public policy matters. All expressions of opinion are those of the speaker(s). To join the debate, please email us at [email protected].

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