I have a problem with that article. It states that transfer pricing is an issue with supposed water's edge corporations. The whole reason we have the water's edge corps is to encourage outside investment in the US. Face it, the labor in this country is expensive. You want Asian and European investment? You got to let them transfer some of the profit back home. Else, they will just build it in the "world's factory floor" in China.
One thing this artilce leaves out is the amount that corporations pay in payroll taxes. They still pay that even if they don't make a profit. Working for a water's edge corp, I know full well that we barely make a profit. We still pay a good chunk to local, state (in sales/use tax), and federal income tax. Even though there is legal transfer pricing going on in my company (which we have to do a study for the IRS every few years), the switch to a huge corporate owner in Japan has created more jobs in the US (because of all the stupid reports we produce).
Not saying that is happening everywhere, but when you focus on just the tax on profit you are missing the whole picture.