I do not recall a loan being made that was not in accordance with the guidelines.
Had there been some cash pooling?
The facts and circumstances of each case must be reviewed to determine if, in substance, there has been a repatriation o...
Was there an ability to move funds from one pool to the other?
I understand. But it was designed by your tax department.
And so your analogy does not relate to the U.S. tax reality. It relates to a theoretical reality.
Must they be made within those windows?
It is kind of lumped together, though, in that slide.
Was it just flat out the most important source of U.S. liquidity?
It just violates, it seems to me, everything which you folks should be about, which is trying to get to substance and tr...
Are there more than a handful in the last few years that have gone to trial on transfer pricing issues?
Does that look like a schedule to you?
So there should be no loans between the two as that might give the IRS the argument that the CFC was merely a conduit fo...
When and how much of the offshore cash pools would be utilized closely coordinated by both of those offices?
There is no possibility with these sequences of there being a gap between available pools.
It is a significant factor in all our transfer pricing policies, cost sharing or not.
How many of these transfer pricing matters has the IRS litigated over the last 10 years?
Am I reading that correctly? 'HP's tax strategy influences the location of cash balances.' Is that your document?
