Carl Levin

If you believed, if FASB believed that APB 23 was being used by multinational corporations as a way of managing their earnings, would you view that as a problem?

It cannot be a short period.

Give me a period of time and tell me how many loans were----

That is all right. I think that is as much as we are going to get on that one.

Does tax strategy influence the location of cash balances?

I think that means the answer is yes.

Are they litigated in Bermuda?

Is the reason it is located in Bermuda to reduce taxes?

So of the $6.3 billion in revenues that come in from sales in the United States, $1.9 billion goes to the United States and the rest stays in Puerto Rico. Is that correct?

Thank you very much, Dr. Coburn.

Would you consider two CFCs which are part of the same company, wholly owned, directed by the same desk, as to when loans would be made or could not be made?

Are those kind of facts relevant to an examiner? That is a pretty straightforward question.

Was that rule in existence during the entire time you were acting as auditor?

How many days were there loans outstanding?

Shouldn't that be avoided?

So the treasury decided within each fund how much and when?

Would you agree that if this were one pool it would not comply with Section 956?

Does it define the windows for loans?

Could you sell from the United States without those kind of cost-sharing agreements with yourself?

So Microsoft, which globally put a consolidated bank account there and balance sheet, is, you say, risking some of its own money--fair enough--assigning some of that risk to a Bermuda entity to reduce taxes, and every year is shifting…

The IRS has broad authority in other respects under Section 482 with respect to companies under common control.

And the IRS should aggressively require that.

There is also another factor, that we are not going to be able to compete with a zero or a 2-percent or a 4-percent tax rate, are we?

Is there any limit under the current regulations to what percentage could be attributed to an offshore wholly owned corporation?

Well, how can an arm's-length standard be applied when you have a wholly owned subsidiary, a controlled foreign corporation, where you are setting some kind of a price for an asset that is being transferred?