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Is the United States giving state aid to Apple? by Stephen L. Curtis

By: Curtis, Stephen L.
Material type: TextTextSubject(s): PRECIOS DE TRANSFERENCIA | AYUDA ESTATAL | EMPRESAS MULTINACIONALES | IMPUESTOS | DERECHO COMUNITARIO EUROPEO | TAX RULINGS | UNION EUROPEA | IRLANDA | ESTADOS UNIDOS In: Tax Notes International v. 117, n. 3, January 20 2025, p. 437-464Summary: In this report, Curtis evaluates Apple Inc.’s impending tax payment to Ireland on its reported stateless income in light of disclosed facts suggesting that those taxes (and more) might be owed to the United States for the same planning, and he considers whether a waiver of those taxes by the IRS would constitute unfair state aid to Apple by the United States.
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OP 138-Bis/2025/117/3-4 (Browse shelf) Available OP 138-Bis/2025/117/3-4

In this report, Curtis evaluates Apple Inc.’s impending tax payment to Ireland on its reported stateless income in light of disclosed facts suggesting that those taxes (and more) might be owed to the United States for the same planning, and he considers whether a waiver of those taxes by the IRS would constitute unfair state aid to Apple by the United States.

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