This is just downright false. There is an entire field inside the tax world called transfer pricing. You cannot just transfer significant IP to a foreign entity for $1 and expect that you will only need to pay tax on that $1. The IRS will come up with its own determination of what the value of the transferred asset is if it disagrees with your valuation and assess taxes based upon that. Now companies and the IRS frequently disagree on what the value should be and do end up in court. Law firms have teams of in-house economists to build defensible models of what the value of the transferred asset should be. Additionally the OECD has issued significant guidance on the topic.