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The cost sharing regime of the United States enables multinational enterprises (MNEs) to export US intangible property to low or no tax jurisdictions, essentially tax-free. This is in stark contrast to long-standing US policy and the explicit tax agenda of the Obama administration. Two recent cases have circumvented attempts by the Internal Revenue Service (IRS) to mitigate cost-sharing-based tax avoidance. This article explains the regime and how the insistence of the IRS on arm’s length-based transfer pricing rules contributed to the current non-taxation of foreign income of US MNEs and explores alternative reforms.
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