Foreigner’s Apple Data Is Fair Game for IRS Summons, DOJ Argues

July 15, 2025, 2:50 PM UTC

The US government should get access to the Apple Inc. accounts of a dual citizen of Italy and Switzerland to aid a foreign investigation of his taxes, it told the US District Court for the Northern District of California.

The Department of Justice defended IRS third-party summonses against Cristian Caruso, about whom the tax agency is seeking records spanning from 2016 to 2023. The US moved for summary denial of his effort to halt the summonses, saying that the IRS was acting at the behest of the Swiss government and in accordance with US international treaties.

“This is a straightforward ...

Learn more about Bloomberg Tax or Log In to keep reading:

Learn About Bloomberg Tax

From research to software to news, find what you need to stay ahead.

Already a subscriber?

Log in to keep reading or access research tools.