Well DD - I don't think your reply does justice to the question.
I have no doubt that distributions from related companies can cause taxation.
But the question is better put whether a US corporation that does an inversion and has huge cash ex-US can thereafter lawfully bring that cash back to the US after the inversion without it being taxed.
I still expect it can and will happen - and be one of the reasons for doing the inversion.
Not sure I understood Moutons answer well enough to say he answered this.
ij
It is astonishing what foolish things one can temporarily believe if one thinks too long alone ... where it is often impossible to bring one's ideas to a conclusive test either formal or experimental. J.M. Keynes