The EU Apple Case : Who Has a Dog in the Fight?

This is a reductionist article. It provides a simplified diagram and explanation of Apple's foreign tax planning that eliminates complexities not necessary to an understanding of either the relevant EU or U.S. tax issues. The primary focus of the article is identification of the stakeholders in the controversy over the EU Commission's Apple decision, analysis of their interests, and evaluation of the impact of the Apple decision on those interests. Finally, the article explains that but for the deferral feature of U.S. international income tax law, the Apple case would not have happened