Carl Levin actually said...

So of the $6.3 billion in revenues that come in from sales in the United States, $1.9 billion goes to the United States and the rest stays i...

Does tax strategy influence the location of cash balances?

Thus, it appears that both courts and the IRS may seek to apply substance over form to transactions that it views as abusive.

Of course you could lend from one to another. But that would violate Section 956.