A very informative article from Kenny Dettman that discusses the possibility of tax-free repatriation of IP to the U.S.  Companies should also be aware of the possibility of incurring exit taxes in the distributing country.  

As these exit taxes could be based on the fair market value of the IP in the distributing country, at a minimum, a high level understanding of the fair market value of the IP is important to understand the potential implications of repatriating IP to the U.S.