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Cramer: A 'Who's Who' of Tax-Domicile Targets

NEW YORK (Real Money) -- That's it, I have had enough. With today's Medtronic (MDT - Get Report)-Covidien (COV) tie-up, it pays to just explore the lunacy of what's known as tax inversion and come up with a "who's next" list of takeover targets.

Even though Covidien is ostensibly located in Mansfield, Mass., its principal executive office is listed as 20 Lower Hatch Street, in the fine city of Dublin, Ireland. While I have been recommending Covidien ever since the breakup of Tyco (TYC), in part because of a series of terrific patient-monitoring and blood-flow devices, it appears that Lower Hatch Street address in Dublin was the main reason it got a bid from Medtronics. Why not? As long as 20% of the new shares go to the acquired company, a huge amount of taxes are saved, and overseas cash can be deployed in a much more tax-efficient manner, given the high U.S. corporate tax rate.

So let's figure out, using that pattern, what's going to happen next.

Located not too far down the road from Covidien is Eaton (ETN), a terrific electronics company that's known for fantastic products in everything from lighting and the electric grid to aerospace and trucking. Yep, you may have thought that Eaton was the corporate pride of Cleveland, Ohio, not unlike the Cleveland Browns, Cavaliers or the tribe itself. Wrong! Eaton is located at Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, Ireland. I stayed at the Four Seasons in Dublin once. Had I timed it better, I could have gone to Eaton's annual meeting, which gets held there.

I think Emerson (EMR) or Honeywell (HON) could save themselves a heap of taxes by buying Eaton. It has the added advantage, like Covidien, of being a terrific company, too.

Covidien is a function of a spin-off from Tyco, not unlike TE Connectivity (TEL), the old AMP. You know AMP, don't you? It's the proud Pennsylvania connector company that was purchased by Tyco for $11 billion back in 2003, during the heyday of convicted felon Dennis Kozlowski. Did you know that TE Connectivity is actually located on Rheinstreasse 20, CH 8200 in Schafhausen, Switzerland?

I can't think of a better place for Washington, D.C.-based Danaher (DHR) to relocate to, can you? The fit is pretty darned perfect, too, given all of that instrumentation that Danaher has.

Or would it be better if it bought Pentair (PNR)? That's another Schafhausen, Switzerland company that also has a U.S. presence in Minneapolis, Minn. That fluids-control business of Pentair's is a difference-maker, although it doesn't make as big a difference as the tax domicile does.

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