Caterpillar offices raided in probe over Swiss unit

CHICAGO - Federal law enforcement officials raided three central Illinois facilities of manufacturer Caterpillar on Thursday as part of an investigation that the company said might be related to business with its Swiss subsidiary CSARL.

Federal agents were seen wheeling large boxes into the Peoria, Illinois, headquarters of Caterpillar, one of the world’s largest makers of construction and other heavy equipment. Facilities in East Peoria and Morton, Illinois, also were searched under a federal warrant, U.S. Attorney’s office spokeswoman Sharon Paul said.

“We believe the execution of this search warrant is regarding, among other things, export filings that relate to the CSARL matter,” Caterpillar said in a statement later Thursday, referring to its Swiss subsidiary.

Caterpillar spokeswoman Corrie Heck Scott wrote in an email that the company was cooperating with law enforcement.

Paul said the agencies involved included the Internal Revenue Service’s criminal investigation unit, the U.S. Department of Commerce Office of Export Enforcement, and the Federal Deposit Insurance Corp.’s office of inspector general. She declined to comment further on the details of the investigation.

The warrant came more than two years after the SEC notified Caterpillar that it was conducting an “informal investigation” relating to CSARL and asked the company to preserve relevant documents.

A 2014 report by U.S. Senate Democratic staff said Caterpillar had avoided paying $2.4 billion in U.S. taxes since 2000 by shifting profits to a wholly controlled affiliate in Switzerland.

The report said Caterpillar paid PricewaterhouseCoopers LLP $55 million to develop the tax strategy. Under the strategy, Caterpillar transferred the rights to profits from its parts business to a wholly controlled Swiss affiliate called CSARL, even though no employees or business activities were moved to Switzerland, the report said.

In exchange, CSARL paid a small royalty, and the income was taxed at a special rate of 4 percent to 6 percent that Caterpillar negotiated with the Swiss government, the report said.

Before the arrangement, 85 percent of the profits from the parts business were taxed in the U.S., the report said. Afterward, only 15 percent of the profits were taxed in the U.S. The rest was taxed at the special rate in Switzerland, the report said.

Last month, Caterpillar said in a filing with the SEC that it was “vigorously contesting” a notice from the IRS that it owed $2 billion more in U.S. taxes for the years 2010 to 2012 from profits earned by the Swiss unit CSARL.

“We believe that the relevant transactions complied with applicable tax laws and did not violate judicial doctrines,” Caterpillar said.

Shares of Caterpillar, which have risen 35 percent over the past year, went into steep decline just before noon as word of the raid on company headquarters and other facilities began to spread, falling almost 5 percent before recovering slightly to close at $94.36.

In January, Caterpillar announced it plans to move its global headquarters and about 300 top jobs to the Chicago area after decades in Peoria. Caterpillar also scrapped plans to build a new headquarters in downtown Peoria, about 175 miles southwest of Chicago.