11/19/2014
https://www.congress.gov...
"There is also another factor, that we are not going to be able to compete with a zero or a 2-percent or a 4-percent tax rate, are we?"
"Was it just flat out the most important source of U.S. liquidity?"
"Was there an ability to move funds from one pool to the other?"
"The facts and circumstances of each case must be reviewed to determine if, in substance, there has been a repatriation of the earnings of the controlled foreign corporation."