id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2841	Azam, Rifat	Minimum Global Effective Corporate Tax Rate as General Anti-Avoidance Rule	2017	51	.pdf	application/pdf	27813	1117	43	In addition, the inversion is excluded from Section 7874 if the affiliated group of the newly inverted foreign corporation has “substantial business activities” in the foreign country.106 In between these two thresholds (60%-80%), Section 7874 imposes U.S. tax on the “inversions gains” which generally refer to certain gains from transfers related to the inversion transactions. I totally agree with Shaviro who supported the enactment of an “exit tax” that “could be based on the amount of U.S. tax that the company would have paid had it repatriated all of its earnings just before the change in legal status occurred.	cache/taxlaw-2841.pdf	txt/taxlaw-2841.txt