Carl Levin actually said...

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?

So there should be no loans between the two as that might give the IRS the argument that the CFC was merely a conduit for repatriating funds...

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 th...