Apple names some of its most opaque holding companies after kinds of apples.
Apple is a vast company, with hundreds of subsidiaries, and operations in most countries. But the companies named after types of apples stand out.
Apple’s made apple puns before. It named its line of computers after the Macintosh apple. But since then, the company hasn’t named many products after apple varietals.
Instead, it names holding companies after the fruit — not for obvious types like Red Delicious or Granny Smith, but usually a more obscure type of apple.
Apple has used some of these subsidiaries to reduce its tax bill, the New York Times reported in 2012, and Congress investigated in 2013, using a system called the Double Irish arrangement, which was eliminated in 2015.
Apple potentially faces what analysts have estimated to be as much as an $19 billion bill (or as little as $100 million) from European Union regulators over its Irish operations, although reportedly the EU investigation does not have anything to do with the Double Irish arrangement. That decision is expected to be handed down this fall.
Apple continues to employ holding companies named after apple types. Here are the ones we know about:
Apple created a new subsidiary called Apple Data Services Ireland in 2015. It's not immediately clear what falls under the subsidiary, but one possibility is that Apple is building a data center in Ireland which received approval earlier this week.
Apple Data Services Ireland was registered in late 2014 under the name Oconee. It lists Gene Daniel Levoff, Apple's VP of corporate governance, as a director.
(image url='http://static.businessinsider.com/image/57ae271fdb5ce951008b6743/image.jpg' alt='Apple Data Ireland' link='lightbox' size='secondary' align='right' nocrop='false' clear='true')
According to an annual report filed in July, there are 7000 shares of the company. Bramley General Partnership owns one of those 7000 shares.
Its address is listed in Delaware, at a location it shares with hundreds of thousands of other companies. The address is also shared with Coca-Cola, Walmart, and American Airlines.
Because it is registered as a partnership, the Delaware government does not have records of who its directors are.
Apple did not respond to a request for comment.
The other company listed as an owner of Apple Data Services Ireland is Akane LLC. It's listed at the same Delaware address as Bramley GP and it was first registered in early 2015.
It owns 6,999 shares of Apple Data Services Ireland.
Akane is 'one of the best early-season apples,' according to Orangepippin.com, and was originally developed in Japan in 1937. Most people eat Akane apples fresh and out of hand.
The most famous of Apple's apple-y subsidiaries is Braeburn Capital, which manages and invests Apple's money. It's based in Reno, Nevada, because the state has a corporate tax rate of zero. Apple lists it as a subsidiary on SEC forms.
Instead of turning to asset managers like Vanguard or Pimco, Apple prefers to manage its own money.
Because Apple has so much money, Braeburn manages tens of billions of dollars -- competitive with many hedge funds. It buys a lot of shorter-term bonds, according to Bloomberg.
According to the New York Times, it's a small office with only a few employees, mostly financial analysts.
Baldwin Holdings Unlimited is listed on most of Apple's major Irish subsidiaries as a member and owner.
Apple Operations International, for example, lists in an annual report filed in 2015 that there are 726,059 shares of the company. Apple Inc holds 700,053, Apple UK holds 26,005, and Baldwin Holdings Unlimited holds one share.
Baldwin Holdings Unlimited is a nominee shareholder with a Virgin Islands address, and the New York Times reported in 2012 that Peter Oppenheimer, former Apple CFO, was the company's only listed director.
'Moreover, the second Irish subsidiary -- the 'Double' -- allowed other profits to flow to tax-free companies in the Caribbean. Apple has assigned partial ownership of its Irish subsidiaries to Baldwin Holdings Unlimited in the British Virgin Islands, a tax haven, according to documents filed there and in Ireland.'
Levoff is also listed as a director of Gravenstein Inc in Apple Data Services Ireland documents from 2015. A Gravestein Inc is located at the same Delaware location as Akane and Bramley GP, and was incorporated in 1997.
Gravenstein is a kind of apple native to Denmark but may be better known as an apple commonly grown in Northern California.
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