This particular ruling was only permitted to go back 10 years. Where are you getting the 25 year number from? Also, I'm unaware of how profits are calculated i

This particular ruling was only permitted to go back 10 years. Where are you getting the 25 year number from? Also, I'm unaware of how profits are calculated internationally, but it seems to me that by sending the money to the US it should no longer be on the international sheets for taxation. That is, US company "charges" the foreign company $x, usually as a "licensing fee". That $x would be a "cost of business" and should offset foreign profits by the same amount. Grand total is that the $x is only taxed in the US on the US company. Now, if they earn that $x in 2015 and send it the US in 2016, sure that particular $x is technically double-taxed. However, the offset is that $x in 2016 is not taxed at all. So again, a wash -- money is fungible and it doesn't really matter when it came from.