Are those kind of facts relevant to an examiner? That is a pretty straightforward question.
Does tax strategy influence the location of cash balances?
That is all right. I think that is as much as we are going to get on that one.
There is nothing heinous in that. There is nothing illegal in that.
Does that not create a presumption that this is obviously not a fair price that is being paid?
Two pools, both HP pools, were given a common schedule.
The IRS has broad authority in other respects under Section 482 with respect to companies under common control.
Could you sell from the United States without those kind of cost-sharing agreements with yourself?
Does it define the windows for loans?
It cannot be a short period.
Why don't you do that.