@evildictaitor: hmmm. Not sure the intellectual property fact matters. Intellectual property wasn't sold. Product was sold. If AOI created the product on their books (their costs at this point) then sold the products on their books (their revenue at this point), the profit on AOI books is taxable to AOI's jurisdiction. Now when that money is transferred from AOI to Apple Inc., then Apple Inc.'s book incurs the income and at that point falls under the jurisdiction of Apple Inc. (I'd imagine AOI would keep the income on their book until a more favorable transfer could take place to bring the money back to Apple Inc.)