By Philip Morrison, Esq.
McDermott Will & Emery, Washington, DC
For decades U.S. multinationals have attempted to create structures that allow them to allocate income from intangible property (IP) to low-taxed CFCs. Over the same period, the IRS has fought to move much of that income back to the United States. This struggle is why the §482 regulations are as long and complicated as they are. It has spawned a sizeable cadre of transfer pricing economic experts and lawyers.