SB_85 Page 22 Jessen the present uncertainty and administrative burden created by the existing regulations.” The Department of Treasury and IRS are in disagreement with this recommendation. An article on separate accounting in the 1976 Harvard Law Review suggested that multinational corporations (uNcs) have considerable flexibility in_shifting income among countries due to the rules they use for pricing transfers between affiliated firms: While tax avoidance may enter into @ MNC's determination of transfer prices, there are many important nonincome tax influences on such decisions. Whatever the motivation, however, freely established transfer pricing represents a means whereby NNC profits produced by subsidiaries in countries with high tex burdens may be shifted to other entities subject to more favorable tex treatment. Whenever transfer pricing has the effect of shifting income in this way, @ country in which economically significant activities took place is deprived of some portion of its feir share of the taxable income of the MNC. ("Multinational Corporation ‘and Income Allocation under Section 482 of the Internal Revenue Code", Harvard Law Review, Vol. 89, No. 6, April 1976, pp. 1203-1204.") Provisions in this bill seek to overcome some of the problems of "arm's length" audits, by beefing up information reporting requirements and by requiring the federal government to provide more resources to such audits. Wil] the additional resources be enough to overcome these problems? $B 85 Fage 22