Re: Tax inversions/transfer of ex-US profits to US
[US] tax law today views overseas earnings that have not been repatriated as part of the U.S. tax system, regardless of whether a company has inverted. Therefore, those past foreign earnings, if repatriated to the U.S., are still subject to full U.S. taxation.
This feature of the US tax code was noted in #msg-102167822.