In a filing to the U.S. Securities and Exchange Commission, Apple said it had set aside $713 million for its 2012 foreign tax bill on overseas pretax earnings of $36.8 billion — a provision of almost 2 percent of what it made.
Google's overseas revenues accounted for 54 percent of its total, including more than 10 percent in Britain alone. Meanwhile Google is tackling government action on another front. German politicians are considering imposing a so-called Google Tax — a levy that would require search engines to pay each time they link to media content like newspaper articles or photographs.
According to a Senate committee memo from September, Microsoft used aggressive asset shifting to avoid $4.5 billion in American taxes from 2009 to 2011.
Avi-Yonah estimated the effective tax rate on overseas income at around 2 or 3 percent for multinational tech companies: Both in the U.S. and abroad, he said, "there's a general sense that these companies pay too little and don't really contribute their fair share."
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