Carl Levin

So you never audited your own tax advice and the implementation of that advice in HP's operations?

Why don't you do that.

Seventy-two days out of 700 days. Is that correct?

The record is going to speak for itself on that statement of yours.

It is kind of lumped together, though, in that slide.

Was it just flat out the most important source of U.S. liquidity?

It just violates, it seems to me, everything which you folks should be about, which is trying to get to substance and trying to get through form.

The goal is to have a tax policy that is transparent, that is reproducible, that is fair, that does not allow people to avoid taxes

Are there more than a handful in the last few years that have gone to trial on transfer pricing issues?

I do not recall a loan being made that was not in accordance with the guidelines.

Does that look like a schedule to you?

Had there been some cash pooling?

So there should be no loans between the two as that might give the IRS the argument that the CFC was merely a conduit for repatriating funds from other foreign sources.

The facts and circumstances of each case must be reviewed to determine if, in substance, there has been a repatriation of the earnings of the controlled foreign corporation.

When and how much of the offshore cash pools would be utilized closely coordinated by both of those offices?

Was there an ability to move funds from one pool to the other?

There is no possibility with these sequences of there being a gap between available pools.

I understand. But it was designed by your tax department.

It is a significant factor in all our transfer pricing policies, cost sharing or not.

And so your analogy does not relate to the U.S. tax reality. It relates to a theoretical reality.

How many of these transfer pricing matters has the IRS litigated over the last 10 years?

Must they be made within those windows?

Am I reading that correctly? 'HP's tax strategy influences the location of cash balances.' Is that your document?

If there were a problem here in the misuse of this assertion, in fact, it is being used routinely to avoid the disclosure in that report in APB 23.

I think it is just way too ambiguous.