OK. And the key contacts in Caterpillar for you were the people in the company's Tax Department. Is that correct?

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?

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.

The head of this effort, the driver of this effort, the one who is going to decide whether or not a dealer stays in or is not going to be allowed to stay in is Mr. Levenick in Illinois.

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

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

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

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

And then would that not have an ongoing tax impact to Caterpillar because CACO is in the United States?

Obviously you do not know what a definition is.

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

That is a chart we are going to put up.

Are those not crown jewels of a company?

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.

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

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

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.

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 allocation of profits was shifted.

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

I am asking you just a very simple question based on your experience.

But that is one relevant fact.

Now let us get down to CSARL.