03/14/2013
https://www.congress.gov...
"That was its purpose. Right?"
"But wasn't the purpose to shift profits for tax purposes to a low-tax jurisdiction. Is that correct?"
"Is it fair to say that the driving force behind . . . CSARL was the tax department and not any business unit?"
"The U.S. parent asserts, could assert that because the risk has been transferred, the offshore affiliate is entitled to the lion's share of the business profits."