The HEART Act has implemented an expatriation tax on certain individuals who renounce their US citizenship. This tax however does not seem to apply to corporations which perform tax inversions in order to offshore tax liabilities to other locations.
Through amateur reading of this act it seems as though a corporation fits the criteria of an individual, meets the income criteria, and meets the meaning of having renounced citizenship.
Though I do not know the tax structure of an inversion, it would seem as though having to pay a tax on all capital a company owns would make this move completely unrealistic from a financial perspective.
Am I misunderstanding the application of the HEART act?
Is the HEART act being applied to these corporations?
If the HEAR act is not being applied, why not?