27 Pages Posted: 3 Jun 2013 Last revised: 30 Aug 2013
Date Written: June 3, 2013
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.
Expert Witness Testimony Submitted on May 21, 2013 for the US Senate Permanent Subcommittee on Investigations.
Keywords: International tax planning, Apple, US Senate Permanent Subcommittee on Investigations, shifting income, base erosion, profit shifting, Subpart F, CFC look-through rule, contract manufacturing, tax gimmicks, effective tax rate
Suggested Citation: Suggested Citation
Harvey, J. Richard (Dick), Testimony of J. Richard (Dick) Harvey, Jr. Before the U.S. Senate Permanent Subcommittee on Investigations May 21, 2013 (June 3, 2013). Villanova Law/Public Policy Research Paper No. 2013-3051 . Available at SSRN: https://ssrn.com/abstract=2273653 or http://dx.doi.org/10.2139/ssrn.2273653
By J. Harvey
By J. Harvey