“The individual defendants, aided by PwC, knowingly cause Caterpillar to engage in an improper, illegal and possibly criminal course of conduct spanning more than a dozen years.” According to the complaint, one PwC employee discussing the alleged scheme over email with a manager said they would need to “do some dancing” to defend the transaction to tax authorities, but the manager replied that they would both “be retired” before the IRS would conduct an audit.
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