You are a working for a large multinational manufacturing firm that has operations in 37 countries, mostly in Europe, North and South America, and Southeast Asia. Some of your companys competitors in the United States have recently been subjected to transfer pricing audits by the IRS. Your controller has asked you to prepare a briefing tax memo concerning transfer pricing Audits. The memo should cover the issues of why the IRS is motivated to conduct them, and what your company can do to either avoid such Audits or mitigate the burden should one be conducted.