So from the beginning, the decision to use CSARL and direct Caterpillar's non-U.S. profits to Switzerland was to shift profits to a low-tax jurisdiction.

And how much, if you repatriated, would be subject to tax here?

But it is a low-tax jurisdiction under your own documents, and that was one of the purposes of these transfers.

They were transferred to CSARL, the economic rights to those? Is that not true?

I am as enthusiastic a supporter of American manufacturing as there is.

I think it is you would not answer that no. But you can answer it no because nobody in their right mind would sell to an unrelated party what Caterpillar transferred in that license agreement for nothing.

That is a chart we are going to put up.

the "unnecessary middleman" is absurd--to call Caterpillar Inc. an "unnecessary middleman is utterly absurd.

What does this mean, 'tax-efficient repatriation strategies,' and why can't you just--it says $3 billion.

Well, then let me tell you that it does, and if it is not true, you can correct for the record what I am saying.

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.

All right. Thank you so much, and thank you again for being here and your cooperation with our Subcommittee.

And this was the marketing company for Latin America, Canada, and the Caribbean?

Caterpillar's Swiss strategy is not the result of conscious policymaking to support American manufacturing.

Are those not crown jewels of a company?

Cat Inc. has the largest role with regard to market and dealer development.

It continues to be involved with the development and oversight of worldwide marketing programs and approaches.

Regardless of how many taxes you currently pay or do not pay, that must be met.

No, I was asking you whether you would offer this--I thought you were making an offer right now to a third party to buy all that.

We cannot tolerate the loss of our taxable revenue the way it is currently lost to Uncle Sam.

Would you have transferred all that, all of that that was in the licensing agreement to anybody but a related party?

Are patents, trademarks, know-how, are they not crown jewels of a company?

I have to agree with Senator Portman about the need for the tax code to be totally reformed.

What I do not support is making this a competition to see who has the most creative tax lawyers.

You have seen it. But you just never heard it described as a virtual one?