Since these are felony allegations (criminal not civil) IRS investigators should sit a few of these CFOs down in a cement room and ask: "Does any of this money come back to the US?"
Then the CFO has a few options: 1) lie to a federal agent (not a good plan) 2) plead the 5th (not a good plan) 3) state to a federal officer that none of the money is used, transferred, or used to pay employees of said corporation by proxy.
I would assume these wouldn't go well at all.
Yes I am well versed in the new stories. The entire point is to move funds out of the country and avoid taxes. They aren't investing in Spain's tech future. They will use this money (stolen from the US people) illegally to: produce products overseas by proxy, perform HR functions by proxy, marketing by proxy, etc. All these products/services are then sold under the company and for more US profit.
The crux of my argument is that you won't find a U.S. felony here, no matter how bad you want it.
Whether that's true or not is a task for the courts to decide, but considering that there is a long history of the US government not taxing overseas profit until it comes to the USA, I'd say that this is an indicator that the government has, to date, agreed with the corporations on this.