> [WS:] It certainly was not. Transfer pricing is a standard accounting
> procedure in multidivisional corporations and it has been in place since
> the 1930s. Its main function is to allocate resources within the
> corporation rather than merely to evade taxes. If it is used that way, it
> takes advantage of some enabling mechanism, such as tax laws or loopholes
> in it.
>
> The problem with Apple was not that they relocated their operations to a
> lower tax jurisdiction, but that they failed to declare any jurisdiction as
> their residence for the sole purpose of tax evasion. This failure may be
> criminal. Moving operations to another location is typically justified on
> business grounds of which lower taxes are a part, but failure to claim
> residence serves no business purpose other than tax evasion. They deserve
> justice China-style - death penalty, and make them pay for the bullets.
>
==========================
[And then again, the so-called failure may be nothing of the sort and imposing criminality upon it ex post would be a perfect example of Justice Holmes' " the infernal arbitrariness of law" quip. Hardly deserving of your emotion addled authoritarian approach. Perhaps there is an opening to intelligently revisit the contradictions between corporate governance and democratic governance in a putatively democratic society saturated with taxophobia cheered on by one of the two capitalist parties? There are lots of leftists out there that have even written books published by big time university presses that are worthy of discussion.]
"Apple used technicalities in Irish and American tax law to pay little or no corporate taxes on at least $74 billion over the past four years, according to the Senate panel's findings. The investigation found no evidence that Apple did anything illegal." [WSJ]
"Apple’s $102 billion in offshore profits is actually managed by one of its wholly owned subsidiaries in Reno, Nev., according to the Senate report on the company’s tax avoidance. The money is tracked by Apple company bookkeepers in Austin, Tex. What’s more, the funds are held in bank accounts in New York.
Because the $102 billion is technically assigned to two Irish subsidiaries, however, the United States tax code considers the money to be under foreign control, and Apple is legally entitled to avoid paying taxes on it." [NYTimes]
"Despite reporting net income of $30 billion over the four-year period 2009 to 2012, Apple Operations International paid no corporate income taxes to any national government during that period," the report found.
Apple told the panel that it doesn't believe Apple Operations International "qualifies as a tax resident of any other country under the applicable local laws." [WSJ]