1. How does Ireland tax corporations?
• Definition of residency
• Special agreements
2. Explain the tax structure Apple was using in Ireland
• Who has the right to collect the tax/penalties assessed by
the EU Commission?
• On whose side is the U.S. – Apple or EU?
• Why doesn’t Ireland want to collect the 14 billion Euros and
decided to appeal the EU Ruling?
• Why was the head office of the Irish Companies not taxed by
Ireland?
• How were the Irish branches taxed in Ireland?
• What kind of agreement did Apple sign with the Irish
government? What did it cover? Was it reasonable?
• Why does the head office pay Apple U.S. for R&D? Is the
payment reasonable?
• How do you think the approach by the EU commission with
Apple differ from the approach taken a=with Amazon,
McDonalds, and FIAT, in Luxemburg and The Netherlands?
• How were sales of Apple products in the EU countries
structured – taxable?
• Why no Subpart F income
• How has the TCJA heightened the tension between the U.S.
and the EU community
