Would you consider two CFCs which are part of the same company, wholly owned, directed by the same desk, as to when loan...
Are those kind of facts relevant to an examiner? That is a pretty straightforward question.
Was that rule in existence during the entire time you were acting as auditor?
Shouldn't that be avoided?
Does it define the windows for loans?
Could you sell from the United States without those kind of cost-sharing agreements with yourself?
The IRS has broad authority in other respects under Section 482 with respect to companies under common control.
And the IRS should aggressively require that.
Is there any limit under the current regulations to what percentage could be attributed to an offshore wholly owned corp...
We do need some kind of broader reform of the system, which at the same time as enabling us maybe to cut the corporate t...
And you agreed, I believe, that this was located where it is for tax purposes.
If you believed, if FASB believed that APB 23 was being used by multinational corporations as a way of managing their ea...
Give me a period of time and tell me how many loans were----
I think that means the answer is yes.
Are they litigated in Bermuda?
Is the reason it is located in Bermuda to reduce taxes?
How many days were there loans outstanding?
So the treasury decided within each fund how much and when?
