The Treasury Department’s warning to corporate America about cutting their tax bills via corporate inversions has worn off, said Tim Larson, partner-in-charge of international tax services at Marcum LLP. 'The action last fall by Treasury really acted as nothing more than a stun gun and as I figured corporations would eventually get back on the inversion path,' said Larson. CF Industries Holdings Inc. (CF), for example, said last week it would acquire the European and North American assets of OCI NV in an $8 billion deal that would create a massive global supplier of nitrogen fertilizers. Terms of the deal call for Deerfield, Ill.-based CF to become a subsidiary of a new holding company to be domiciled in the United Kingdom that would also house the European, North American and distribution businesses of OCI. Amsterdam-based OCI would receive 25.6% of shares in the new CF plus $700 million to be paid in cash or stock, with the new entity also assuming about $2 billion in debt. The combination would maintain its headquarters in Deerfield and continue to be listed on the New York Stock Exchange under CF's current ticker. The company said it expects to generate about $500 million in after-tax cost savings from consolidating operations and the lower tax rate. 'As a result of their moving to the U.K. their future foreign cash flow will not be subject to U.S. taxes so it puts them in a much more competitive global position,' said Larson, adding that any move by the Treasury Department to punish CF for the maneuver is highly unlikely.
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