"European Commission State Aid Decision
On August 30, 2016, the European Commission announced its decision that Ireland granted state aid to the Company by providing tax opinions in 1991 and 2007 concerning the tax allocation of profits of the Irish branches of two subsidiaries of the Company (the “State Aid Decision”). The State Aid Decision orders Ireland to calculate and recover additional taxes from the Company for the period June 2003 through December 2014. Irish legislative changes, effective as of January 2015, eliminated the application of the tax opinions from that date forward. The Company believes the State Aid Decision to be without merit and appealed to the General Court of the Court of Justice of the European Union. Ireland has also appealed the State Aid Decision. Although Ireland is still computing the recovery amount, the Company expects the amount to be in line with the European Commission’s announced recovery amount of €13 billion, plus interest of €1 billion. Once the recovery amount is finalized by Ireland, the Company anticipates funding it by placing amounts into escrow in 2018, pending conclusion of all appeals. The Company believes that any incremental Irish corporate income taxes potentially due related to the State Aid Decision would be creditable against U.S. taxes."
The Trump Tax Bill Has a Mandatory Tax on Cumulative Foreign Earnings Provision (Toll Tax) at a Clearly Bargain US Federal Income Tax Rate to Be Paid Over the Next 8 Years. Apple Now Believes If It Pays This Ireland Income Tax That It Is Creditable Against Its Toll Tax.
Thanks Donald Trump and the Republicans in the US Congress For Letting Me and Other US Taxpayers To Now Be Responsible For Apple's US$17.5 Bil Ireland Income Tax Exposure.
