02/17/2007
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..."
"Now, Caterpillar, in its written statement submitted to the Subcommittee, says that even if it were stipulated that the changes made in 1999 were motivated primarily by tax considerations and generate..."
"And how much, if you repatriated, would be subject to tax here?"
"Of course, but that is Caterpillar's offshore employees."