11/02/2011
https://www.congress.gov...
"We codified the economic substance doctrine in 2010 and we stated that the IRS can invalidate transactions that create no meaningful change in the economic position of the taxpayer and have no 'substa..."
"Thank you, Senator Johnson."
"And how much, if you repatriated, would be subject to tax here?"
"Of course, but that is Caterpillar's offshore employees."