IRS to implement tax enforcement case against the company on this issue of the "stateless income," the senior official said on Wednesday, in any country is not taxed profits of an enterprise reference.
Eric Corwin, the IRS deputy chief counsel, international tax disputes with the company, "the most complex restructuring involves creating stateless income or affect the tax consequences of repatriation efficiency."
"So these are a family case, the pipeline was watching," he told tax lawyers in a speech in Washington.
Asked by reporters later elaborated in any litigation, Corwin declined to comment. But tax lawyers say stateless cited by the IRS held outside income and profits may herald a new way of law enforcement.
"The use of the IRS before the expiration, I have not heard," Edward Kleinbard, who coined the term "stateless income", that is a research paper in 2007, said in a telephone interview.
He is the former chief congressional Joint Committee on Taxation staff, now in the University of Southern California Gould School of Law professor.
Concerned about the stateless income, May proposed Senate Permanent Subcommittee on Investigations released a report, found that Apple's APPL.O avoid in 2012 $ 900 million in U.S. tax involves three offshore units to use tax policy is no obvious home or "live."
Avoidance of companies say they are doing nothing illegal, but the government offered tax cuts, job creation and commercial exploitation.
Repatriation of profits has been a U.S. company, jointly owned by more than 150 trillion sitting offshore greatest concern. Most people say they take it home and put the money they will face in order to avoid the tax.
IRS officials days after the opinions, G20, the world's leading economies, a group of 19 countries plus the European Union expressed support for multinational taxation rules fundamentally reassessed.
In the July 19, Economic Cooperation and Development, the proposed tax and economic policy G20, Organization issued an action plan that the existing national tax enforcement system does not work. The program took aim at companies like Apple and Google (GOOG.O) loopholes to avoid billions of dollars in taxes.
U.S. Treasury Secretary Jack Lew said: "We must address the chronic problem of 'stateless income," which undermines our confidence in the tax system at all levels, "Economic Cooperation and Development (OECD) report, on July 19 at a copies of the statement.
 



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