Is that something which we ought to address and end?

I think it is highly dubious, frankly, that the loan program complies with our current tax law.

I understand. In order to avoid the application of Section 956, these were guidelines.

You just said there could be a loan from one.

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

I believe that you said, Mr. Ezrati, that you did not depend heavily upon these funds for your liquidity.

Does that not create a presumption that this is obviously not a fair price that is being paid?

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

But assuming they do not eliminate--I do not disagree at all, but assuming that exception is going to remain, would it not be essential that FASB put out some guidance?

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

Thus, it appears that both courts and the IRS may seek to apply substance over form to transactions that it views as abusive.

I think it is just way too ambiguous.

This Subcommittee has demonstrated in hearings and comprehensive reports how various schemes have helped to shift income to offshore tax havens and avoid U.S. taxes.

What rule would you change?

Had there been some cash pooling?

Must they be made within those windows?

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

That is what the point is here, trying to avoid Section 956.

It cannot be a short period.

The Congress is to blame for some of this.

I think that means the answer is yes.

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

We see in the Microsoft case a very significant transfer of revenue and profit overseas to a wholly owned subsidiary in some cases that has no employees whatever.

And the justification for that under current law should be required, should it not?

We do need some kind of broader reform of the system, which at the same time as enabling us maybe to cut the corporate tax rate will also prevent particularly further profit shifting.