But this case has two points to counter your assertion... - They were receiving income (via interest payments for loans that weren't actually used). - They have

But this case has two points to counter your assertion... - They were receiving income (via interest payments for loans that weren't actually used). - They have a controlling interest in the company - your assertion means they can effectively defer income indefinitely? This was the situation Congress was trying to solve - otherwise we go right back to everybody keeping all their money offshore.