Medtronic PLC and Corporate Tax Inversions

Abstract

This case deals with the very topical subject of tax inversions. In the case, students are initially introduced to the concept of the tax inversion, the process by which a U.S. company reincorporates in another country, often as part of a corporate acquisition. Case participants (students) will learn one of the goals of such a corporate maneuver is to reduce the company's income tax burden. In the first section of the case, students are lead through the actual structuring of the 2014 Medtronic/Covidien inversion. They will be challenged initially to explain the inversion process, the purported benefits, and the likely tax treatment of the companies and shareholders. The student objectives are threefold in section two of the case. First, the students are charged with actually calculating Medtronic effective income tax rates before and after the inversion to attempt to prove a benefit from a decrease in the effective tax rate. Second, case participants will be immersed in the non-GAAP measures the company uses to explain inversion tax benefits. Finally, students are charged with preparing a pro-forma quantification of tax savings for the Medtronic/Covidien inversion and developing an argument as to whether or not it is actually a benefit and sustainable.