Expert Witness Testimony Submitted on May 21, 2013 for the US Senate Permanent Subcommittee on Investigations.


Apple is an iconic US multinational corporation. In addition to demonstrating excellence in designing, building, and selling consumer products, Apple has been very successful at minimizing its global income tax burden. This expert testimony describes how Apple:

• allocates approximately two-thirds of its global income to Ireland, a country where only 4% of its employees and 1% of its customers are located,
• minimizes Irish tax by creating an Irish entity that is managed and controlled in the US, and
• avoids the US Subpart F rules.

More generally, the testimony illustrates techniques used by US MNCs to shift income overseas and avoid the US Subpart F rules designed to tax passive income.

Finally, the testimony makes several tax policy recommendations.


Law | Taxation-Transnational | Tax Law

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