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To: TechMkt who wrote (142593)	9/23/1999 9:22:00 AM
From: rudedog	Respond to of 176388

fez - But, CPQ is a $4 billion, in rvenue, company That's $40B... and no matter how you slice it, a $4M liability is just not significant. In addition, the manipulation of foreign assets is a routine practice for global companies. The idea that over a 10 year period there was a single transaction which got disallowed by the IRS is just no big deal. This was not a crooked transaction or an example of a deep seated problem. Tax rules as applied to international transactions change all the time and have a lot of gray areas which savvy companies always try to exploit. What happens if a company tries something which doesn't get allowed? Well, as in this case, 7 or 8 years later you pay what you would have paid anyway plus a penalty, in this case a maximum of $800,000. As a shareholder I would hope that this does not occupy more than about 10 seconds of anyone's time at CPQ, they have more important things to think about.