Since the Supreme Court has given recognition to the concept of corporate citizenship, to discourage corporate inversion the executive branch should determine that the act of inversion is a renunciation of U.S. citizenship subject to existing law including both Section 349(a)(5) of the Immigration and Nationality Act and the expatriation tax provisions under Internal Revenue Code sections 877 and 877A.
The Expatriation Tax IRC 877A imposes a mark-to-market regime, which generally means that all property of an expatriate is deemed sold for its fair market value on the day before the expatriation date. This includes all domestic and foreign assets, both tangible and intangible, such as factories, corporate offices, financial holdings, patents, copyrights and trademarks.