"Re the Symantec tax isssue, there is a strong possbility they will beat the IRS claim, or if not beat it at least substantially reduce the liability to a a few hundred million. The IRS are basically chancing their arm on this, in the hope that they will get something out of it, or at worst scare a few firms into recognising more taxable revenue in the states. If a transfer price can be shown to be economically justifiable there should be very little they can do."
Im not so sure, i think there is a big change of sentiment by the IRS. The american government needs alot more money to support its spending. Also what Symantec is at is really hurting the american balance of payments. Effectively it is licensing an irish subsidiary to sell american technology in europe as if it were an irish export but the actual technology is developed by its american operation. So basically other countries like ireland and china etc are reaping the benefits by boosting their own balance of payments and government revenue. So I think in future the IRS is going to make it very difficult for multinationals to continue this practice.
