Is it fair to say that the driving force behind . . . CSARL was the tax department and not any business unit?
Now let us get down to CSARL.
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 ...
So you use words, too, 'low-tax [marketing] countries'? Don't you ever use those words?
Should it pay $900 million? That is the question.
If the value of the CACO transfer was treated the same as CSARL's intangibles were, as claimed by Pricewaterhouse, doesn't that create a hug...
That was its purpose. Right?
Would you have transferred all that, all of that that was in the licensing agreement to anybody but a related party?
Now, are those positions reconcilable?
Thank you very much, Mr. Quinn. We understand you are giving the statement for all three. Is that correct?
I think it is Exhibit 13.1A. Is that correct?