Offshore Profit Shifting and U.S. Tax Code Weaknesses: Analyses and the Apple Inc. Case Study

Reny Toupin (Editor)

Series: Economic Issues, Problems and Perspectives
BISAC: BUS069010

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Edited by I Leslie Rubin, Robert J Geller, Abby Mutic, Benjamin A Gitterman, Nathan Mutic, Wayne Garfinkel, Claire D Coles, Kurt Martinuzzi, and Joav Merrick

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On May 21, 2013, the Permanent Subcommittee on Investigations (PSI) of the U.S. Senate Homeland Security and Government Affairs Committee held a hearing that was a continuation of a series of reviews conducted by the Subcommittee on how individual and corporate taxpayers are shifting billions of dollars offshore to avoid U.S. taxes. This book examines those hearings and how Apple Inc., a U.S. multinational corporation, has used a variety of offshore structures, arrangements, and transactions to shift billions of dollars in profits away from the United States and into Ireland, where Apple has negotiated a special corporate tax rate of less than two percent.

This book examines how Apple Inc. transferred the economic rights to its intellectual property through a cost sharing agreement with its own offshore affiliates, and was thereby able to shift tens of billions of dollars offshore to a low tax jurisdiction and avoid U.S. tax. Apple Inc then utilized U.S. tax loopholes, including the so-called “check-the-box” rules, to avoid U.S. taxes on $44 billion in taxable offshore income over the past four years, or about $10 billion in tax avoidance per year. The book also examines some of the weaknesses and loopholes in certain U.S. tax code provisions, including transfer pricing, Subpart F, and related regulations, that enable multinational corporations to avoid U.S. taxes. (Imprint: Nova)

Preface

Memorandum: Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)
(Permanent Subcommittee on Investigations)

Testimony of Apple Inc. Hearing on "Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)"

Testimony of J. Richard Harvey, Jr., Distinguished Professor, Villanova University School of Law. Hearing on "Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)"

Testimony of Stephen E. Shay, Professor of Practice, Harvard Law School. Hearing on "Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)"

Testimony of Mark J. Mazur, Assistant Secretary for Tax Policy, U.S. Department of the Treasury. Hearing on "Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)"

Testimony of Samuel M. Maruca, Director, Transfer Pricing Operations, Internal Revenue Service. Hearing on "Offshore Profit Shifting and the U.S. Tax Code - Part 2 (Apple Inc.)"

Index

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