外國投資者迫使美國年輕企業稅負倒置- 國際稅務評論（2019年4月）

The US Tax Cuts & Jobs Act (TCJA) is failing to prevent inversions, with the lure of foreign capital often outweighing the tax challenges for rapidly expanding businesses.

Inversion considerations for businesses

The lower post-TCJA rate is an incentive to remain headquartered in the US, but also less of a disincentive to leave.

Another consideration for emerging businesses and their Asian investors is GILTI. "The imposition of GILTI would be of particular concern to a Chinese company holding investment in a US Company .This is quite common," said Anthony Tam, a tax partner at Mazars Hong Kong.

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Credits: Danish Mehboob for International Tax Review, 1 April 2019