Is it not true that PwC had an ongoing program called Global Tax Optimization Program (GTOP), to reduce corporate taxes? Is that true?

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

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

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

Now, at the same time, Pricewaterhouse performs two functions; in other words, it is Caterpillar's independent auditor, but it is also its tax consultant.

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.

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

Now, prior to the tax consulting engagement, Caterpillar had been reporting most of the income from the sale of its replacement parts outside of the United States on its U.S. tax return. Is that correct?

So the advantage to Caterpillar Inc. would be that it would pay less Federal income tax?

That is a chart we are going to put up.

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.

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

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.

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

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.

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

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

Are those not crown jewels of a company?

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

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

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

I am just asking you a question. It was not impacted by that major change in how the taxes were going to be paid. Is that correct?

I think every corporate executive in the world would answer that, but you in front of this Subcommittee.

A minute before the red light comes on on the timer, you will see a light change from green to yellow, giving you an opportunity to conclude your remarks.