Would the facts I gave you be relevant, that you have one desk that controls the loans of both those entities?

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

But there is a heavy cost to the United States.

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.

Are those facts relevant to whether or not there was an arm's-length agreement which led to a transfer agreement which resulted in the $2 billion payment?

Does that look like a schedule to you?

Is that what you mean by sequence?

But 'indefinitely' could mean no definition.

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.

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?

If check the box were eliminated, there would be more taxation under Subpart F.

Is it appropriate to use it as a tool to manage earnings?

Does tax strategy influence the location of cash balances?

Every time, though, a Microsoft product is sold, 47 percent of the sales price is sent to Puerto Rico where Microsoft pays no tax.

The word says 'schedule.' Read that to me. 'The following schedule.' Why don't you read it?

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?

Why don't you do that.

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…

All right. So Microsoft Puerto Rico got $1.6 billion from Microsoft's Irish subsidiary called Round Island One. Is that correct?

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

I said it was a schedule when loans could be made and, if they were made, must be made, and must be repaid.

And the IRS should aggressively require that.

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

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

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