Two manufacturing giants have agreed to merge: Johnson Controls (JCI) and Tyco International (TYC). Tyco is headquartered in Cork, Ireland. As part of the deal, the combined company will now be based in Ireland, in a prime example of a corporate inversion. This is where a U.S. company acquires a foreign firm based in a lower tax jurisdiction. The new company is then headquartered overseas, paying a lesser tax rate. In this case, Johnson Controls is set to score $150 million a year in tax savings. Ireland's corporate tax rate is a mere 12.5 percent, compared to 35 percent in the U.S. Over the last decade, there have been 47 corporate inversions, according to Congressional Research Service. TheStreet’s Scott Gamm reports from Wall Street.