They want to avoid triggering a tax? You do not think that is the whole purpose here, they want to avoid triggering a tax?

Well, isn't the tax that is being avoided the corporate tax which would be triggered if it was not qualified income under Section 851?

For 10 years now, this Subcommittee has focused attention on the problem of excessive speculation in the commodity markets.

Thank God now there is a moratorium, but you put your stamp of approval on a mechanism which is inconsistent with what you are arguing in so many cases.

They want to have their cake, which is investing in commodities, and eat it, too, by not paying what the tax would be if they did that directly in the United States.

it is our joint intent that even though there may not be consensus on the effect of speculation, that there is consensus that our laws are intended to be followed

Thank you both. We have a vote that is on now, and apparently there is only 5 minutes left.

Now, do you both agree that if a mutual fund bought and sold commodity futures or a commodity swap--in other words, if a mutual fund made a direct investment in commodities, the income from those investments would not qualify as income…

Well, we passed a law in 2010 talking about economic substance saying that something has got to be real, it cannot be fake, and we are going after these totally phony transactions, which is what this is acknowledged to be. It is a shell…

I am delighted to be here today to introduce Judge Gershwin Drain, whom the President has nominated to the Federal bench.

They acknowledge it. But then when the IRS says they are going to allow that to be used, it undermines all the efforts we are making.

Does the IRS care about people circumventing our tax laws through the use of shell/sham corporations offshore?

the moratorium on these letters which they have sent, which gives the green light to specific mutual funds to proceed in this area, runs right into a number of doctrines.

Again, we are grateful for your appearance here today.

So now the question is whether or not they can avoid that impact by creating a shell corporation, which everyone agrees is a paper corporation with no business purpose, no economic purpose down in the Caymans.

We have been hurt at the pump, we have been hurt at the dinner table, and we have been hurt in our pocketbooks.

Now, why do you think mutual funds are setting up these corporations offshore rather than here in the United States?

Statement submitted by Senator Carl Levin

Thank you again for inviting me to testify. I look forward to responding to your questions.

Iraq's relationship with Iran is exceedingly complex and multifaceted.

leaving Iraq on the terms dictated by its sovereign government will put to bed the very real perception that the United States invaded the country to transform it into its '51st state.'

I think there is a lot of concern in Congress about it, and this will, I believe in my opinion, severely negatively impact their relationship with the U.S. Congress.

You said you helped manage the negotiations on whether and how to extend the December 2011 deadline for the withdrawal of U.S. troops.

I do think we should take a long view of this thing.

The U.S. military presence in Iraq was a source of recruitment for Iranian-backed extremist groups in Iraq.