Apple's Cost Sharing Arrangement: Frankenstein's Monster

This paper performs a forensic analysis of Apple's transfer pricing cost sharing arrangement based on facts and documents that were disclosed in hearings before the U.S. Senate Permanent Subcommittee Investigations May 2013 an investigation arrangements by European Commission between 2016 as part its State Aid investigation, related court filings Europe other sources. The finds Apple provided conflicting information to these different investigations that, when combined, from both investigations, combined with additional research reveal appears have violated laws 2009 later years, should invalidated but apparently not detected IRS. These tax violations resulted federal underpayments we estimate be greater than $84 billion. reserves for Uncertain Tax Positions $16.5 billion September 2020, much less this amount. proposed adjustments under periodic adjustment regulations are limited any statute limitations, appear accompoanied additiional violations, including economic substance doctrine, governing taxation effectively connected income.