Carl Levin actually said...

"Is the purpose of your regulation that they meet arm's-length standards?"

"I think I would characterize the original characterization of Subpart F is to prevent the shifting of passive income abroad, yes."

"The Treasury might be able to fix some of these problems if it would reform check-the-box, develop regs making it easier for the IRS to go after shell corporations that are used for tax avoidance."

"There is a huge drain as a result."