Tax Rules Spur Moves to Repatriate IP: Transfer Pricing Report

March 6, 2026, 10:03 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re exploring how US companies are looking to reverse years of IP offshoring to bring these assets back home — and facing the audit risks and potential expenses tangled up in that. The IRS slams Coca-Cola’s reliance on 3M. And we get a sneak peek at the coming APMA report.

US multinationals are moving ahead with plans to bring their valuable intellectual property back home, in what would be an interesting reversal of years of offshoring and tax disputes over the movement and pricing of intangibles, ...

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