The IRS has explicitly identified transfer pricing as an international compliance initiative for
2010 and beyond. The IRS is motivated by the increases in foreign income reported by U.S.-based
TNCs that have ‘‘tripled their foreign profits between 1994 and 2004, with more than 58 percent of
that profit reportedly being earned in so-called tax haven countries ... [and] foreign-controlled U.S. corporations [are] potentially stripping away profits from the U.S. through non-arm’s-length pricing and potentially abusive financing structures’’ (Ossi and Shepherd 2010, 3)