A new set of proposed regulations from the Internal Revenue Service aims to change the way companies use accounting methods to switch profits from countries with high corporate tax to countries where corporate taxes are low.The regs - all 85 pages of them - create an ambitious regime with a number of nebulous new concepts, including an "investor model," to insure that businesses value intangibles, such as marketing, research and development, and patents, in a way that will maximize exposure to U.S. tax.

"The main drivers of economic value creation and economic growth in American multinational companies are intangible assets, which contribute significantly to an enterprise's competitive advantage. They often have the potential to yield above-average profits, while physical and financial assets are rapidly becoming commoditized," said Selva Ozelli, a CPA and international tax expert.

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