04/26/2010
https://www.congress.gov...
"Now, is that true even if the assets are totally controlled by the parent?"
"This is the first time that we have ever come across entities that have no tax residence."
"Active income deferred, passive income was not supposed to be deferred. Is that correct?"
"The result of continuing that in 2008 and 2009 is most of your profits worldwide are now in three Irish companies that you control that do not pay taxes."