This securities class action alleges that Caterpillar, Inc. tried to evade paying US taxes by forming a Swiss subsidiary, Caterpillar S.A.R.L. through which it would pay Swiss taxes of only 4-6%. However, in order for this to be legitimate, CSARL had to carry out substantial operations and have a real business purpose, which the complaint claims it did not. Throughout a whistleblower lawsuit and investigations by the IRS, the US Senate, and others, the complaint claims that the company insisted its tax position was legitimate and it was cooperating with investigations, while it downplayed the risks of its position, in violation of the Exchange Act of 1934. Finally, the complaint says, the IRS and other authorities raided its US headquarters, marking the end of both the class period and the deception.