The U.S. government is asking a federal court to enforce an IRS summons to Apple for user data, that will be used in a Swiss tax investigation, reports AppleInsider.
Federal prosecutors want a California judge to reject a petition aiming to block the Internal Revenue Service from demanding Apple turn over account records linked to Cristian Caruso who is under investigation for possible Swiss tax liabilities.
Caruso, a Swiss and Italian citizen, is fighting the summons in U.S. District Court in Northern California. He argues the IRS request is overly broad and lacks specific relevance to the Swiss inquiry. The data sought covers subscriber details, connection logs, payment information, and IP addresses from 2016 to 2023.
Caruso filed a lawsuit in the U.S. District Court for the Northern District of California to stop the summons. Caruso claims the summons is too broad and amounts to a fishing expedition. He argues the requested data has little to do with calculating Swiss tax liabilities and points out that he lived in the United Kingdom for part of the period in question.
Caruso’s legal team calls the IRS request amounts a “fishing expedition” and say the data demand fails to meet the treaty’s “foreseeable relevance” standard, which requires a clear link between the requested information and the tax matter at hand. Caruso wants the court to apply existing U.S. legal standards that reject overreaching demands lacking specific justification. If granted, the petition would block the IRS from forcing Apple to share the record.
Meanwhile, the IRS is seeking records from Apple’s headquarters in Cupertino. They include subscriber names and addresses, session times, connection records, payment methods, and IP addresses spanning 2016 to 2023.
