The EU Apple Case: Who Has a Dog in the Fight?

8 Pages Posted: 8 Feb 2017 Last revised: 21 Feb 2017

See all articles by J. Clifton Fleming

J. Clifton Fleming

Brigham Young University - J. Reuben Clark Law School

Date Written: January 9, 2017

Abstract

This is a reductionist article. It provides a simplified diagram and explanation of Apple's foreign tax planning that eliminates complexities not necessary to an understanding of either the relevant EU or U.S. tax issues. The primary focus of the article is identification of the stakeholders in the controversy over the EU Commission's Apple decision, analysis of their interests, and evaluation of the impact of the Apple decision on those interests. Finally, the article explains that but for the deferral feature of U.S. international income tax law, the Apple case would not have happened.

Keywords: EU Law, Income Taxation, International Taxation, International Law

JEL Classification: H20, H21, H25, H87, K34

Suggested Citation

Fleming, J. Clifton, The EU Apple Case: Who Has a Dog in the Fight? (January 9, 2017). Tax Notes, Vol. 154, No. 2, 2017; Tax Notes International, Vol. 85, No. 2, 2017; BYU Law Research Paper No. 17-04. Available at SSRN: https://ssrn.com/abstract=2880048

J. Clifton Fleming (Contact Author)

Brigham Young University - J. Reuben Clark Law School ( email )

430 JRCB
Brigham Young University
Provo, UT 84602
United States

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