In 2014, the pharmaceutical company Pfizer initiated a restructuring, only to encounter impediments from the United States Department of the Treasury, further halting any prospective Congressional action. During this period, the United States had among the highest corporate income tax rates in the world, prompting the Department of the Treasury to scrutinize Pfizer’s actions, characterizing them as an attempted tax inversion. The IRS, in the face of a gridlocked Congress, issued a notice of proposed rulemaking that would begin altering regulations, thereby thwarting numerous existing structures, including Pfizer’s proposed transaction, from securing approval.

In episode four of the “Regulation and Red Tape ” series, experts provide an exposition of corporate tax inversions, spotlighting Pfizer’s case, and raise pivotal questions concerning the balance of powers when time-sensitive policy matters are at stake.


  • John Allison, Former BB&T Executive
  • Richard M. Kovacevich, Former CEO, Wells Fargo
  • Timothy Massad, Consultant; Adjunct Professor of Law, Georgetown Law
  • Host: Hon. Paul Ray, Director, Thomas A. Roe Institute for Economic Policy Studies


As always, the Federalist Society takes no position on particular legal or public policy issues; all expressions of opinion are those of the speaker.