Okay, so maybe G.E. still holds its own against the Cupertino-based computing giant — after all, it did earn a $3.5 billion tax credit in 2010 on over $5 billion profits — but Apple’s tax accountants are clearly world-class. They managed to save the company as much as $2.4 billion in taxes last year, with the company paying just $3.3 billion on $34.2 billion in profits, according to a front-page story in today’s New York Times. (That’s profits, mind you, and that’s in billions, like with a b.) Apple’s tax strategy has been two-fold. First, to avoid high California state taxes, much of the company’s profits were funneled through a Reno-based outfit called Braeburn Capital, which allowed them to take advantage of Nevada’s zero corporate tax. Since it was founded in 2006, Braeburn has earned $2.5 billion in interest and capital gains on Apple profits transferred to its books.
Then there’s that pesky U.S. federal corporate tax of 35 percent to deal with. To avoid this, Apple created what is fondly referred to in the tax avoidance community as a “Double Irish With a Dutch Sandwich” — which New York diagrammed, sans the Dutch Sandwich, last fall. (See the Times’ diagram here.) In a nutshell, it works by moving U.S. profits offshore through Ireland, which has a considerably lower tax rate, and using a complex system of European shell companies — with names like Apple Sales International and iTUNES S.à r.l. — to move as much of the money unobserved through Dutch subsidiaries or into tax-free Caribbean companies. In Apple’s case, it was a British Virgin Islands outfit called Baldwin Holdings, with no offices or phone number. Its sole director: Apple’s California-based CFO.
When all the dust from the year’s flurry of legal paperwork and money transfers finally settled, Apple had paid just 3.2 percent in taxes on foreign profits last year, and 9.8 percent on overall profits. Not too shabby for a year’s work.
