[koralatov]

    > license the U.S.-made IP to that subsidiary for $0.
    > Boom the U.S. company now has no profits to show and
    > all profits are in the low-tax jurisdiction

That seems simple, but the U.S. government are wise to that kind of thing. At a previous job, the U.S. parent company used to supply our spare parts, which we then sold to end-users in Europe. We operated under very strict rules, derived somehow from Sarbanes-Oxley, about how much the U.S. parent had to charge us for these parts to ensure that they weren't simply running up a loss for tax reasons. IP worked the same way.