Given the reaction of the White House, it would seem that Apple does consolidate their tax return with the Ireland "branch" (whatever it is), but I dont know if that's really the case.  Corporations do not HAVE to consolidate their returns.  It's a choice.  If they don't consolidate the return, there would be no foreign tax credit on Apple's return, so the assumption of the foreign tax credit cutting in the tax revenue (hurting taxpayers) would not even be an issue.  They would be reporting income separately like two separate entities.

 

I'm confused how if Apple operations in the US report income to the US, and the Ireland branch reports income to BOTH Ireland and the US, how is that saving money?  I think the answer is they don't consolidate.  Corporations do not have to recognize foreign income of subsidiaries unless the funds are actually transferred back inside the US, hence why Apple would make the Ireland tax haven deal to begin with.  All their profits in Europe can stay in Europe without incurring US tax liabilities. 

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