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Companion legislation introduced in Congress in May by Michigan Democrats and brothers Sen. Carl Levin and Rep. Sander M. Levin, the “Stop Corporate Inversions Act of 2014,” would stop the bleeding, disallowing any more inversions for at least two years while Congress retools what everyone agrees is an outdated tax code. (The Senate version includes a two-year expiration date to stop the expatriation of companies while Congress works out a “grand bargain” on tax reform. The House version of the bill would stop the practice permanently.)

The bill, which mirrors a proposal in President Obama’s 2015 budget, wouldn’t be the first time Congress took on inversions; in 2004, legislation to deter companies from doing this was signed into law by President Bush. But if that effort was a STOP sign to companies looking for ways to avoid paying taxes, this bill appears to be the equivalent of a concrete divider placed across a highway, for it strengthens the current law in three ways: First, through a more stringent “shareholder” test; second, through a new “business activities” test; and finally, through an unprecedented “headquarters” test that would require companies to move most of their executives and management overseas if they wanted to escape U.S. taxation.

The $19.5-billion question is: Will it work? Is this the best way to get after corporate deadbeats and stop the erosion of the U.S. corporate tax base? Or will companies find loopholes in this legislation or other means to dodge the taxman?

Consulting with international tax experts, economists, lawmakers, and others, Remapping Debate found an overwhelming consensus on three points:

First, the Levin bill is, indeed, close to “loophole proof” and would likely save the Treasury billions of dollars for years to come; second, it would reduce the competitive disadvantage that smaller U.S. companies suffer to large, well-heeled multinationals able to exploit overseas tax havens to amass profits; third, the more time passes without legislative action, the more inversions we are likely to see.

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