CUPERTINO (AP) — Apple revamped its overseas subsidiaries to take advantage of tax loopholes on the European island of Jersey after a crackdown on Ireland’s loose rules began in 2013, according to The New York Times and the International Consortium of Investigative Journalists.

The news outlet and the non-profit investigative organization cited confidential records that were obtained by the German newspaper Suddeutsche Zeitung (“ZOOT-doi-cheh DZEYE-tung”) and shared.

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The moves came after a U.S. Senate subcommittee found in 2013 that Apple had avoided tens of billions of dollars in taxes by using overseas havens. The paper said Apple has $128 billion in offshore profits untaxed by the U.S.

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Apple moved the tax home of two Irish subsidiaries to Jersey, a self-governing island in the English Channel between Britain and France. Apple didn’t immediately comment.

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