Mindy Herzfeld (Florida), “Inverting the Tax Landscape: Domestications” (Tax Notes, May 18, 2026):

Cast your mind back 10 years (if you can) to the hottest cross-border tax and mergers and acquisitions strategy of the day: inversions. That term generally encompassed both single U.S. companies reincorporating overseas into tax-favorable jurisdictions and mergers between U.S. and foreign corporations in which the combined company ended up headquartered in a foreign, tax-efficient location.

The inversion trend arose largely because of the lack of parity between the U.S. tax system and those of most other countries. Not only was the statutory corporate U.S. rate much higher than the rates of most other developed countries, but other quirks of the U.S. system (such as full taxation of foreign dividends at a 35 percent rate) made it an imperative for U.S. companies to consider becoming headquartered elsewhere — first in zero-taxed island countries such as Bermuda, and when that lost appeal, under more advantageous tax regimes where the United States had a tax treaty, such as the United Kingdom or Ireland.

How the world has changed — in fact, flipped on its head (or inverted, if you will) — in the past decade.