US Treasury guidance could stop Apple from recouping Irish taxes at home

"We are closing another tax loophole that contributes to the erosion of our tax base," said the Treasury's Assistant Secretary for Tax Policy, Mark Mazur, in a statement seen by Reuters. The guidance limits the scope with which multinational corporations can apply to have foreign tax credits count against their U.S. taxes.

The European Commission recently concluded that Irish tax deals with Apple constituted illegal state aid, and ordered the country to collect $14.5 billion in back taxes from the Cupertino, Calif., company. Both Apple and the Irish government are planning to appeal the decision, the latter because it's worried about losing appeal with foreign businesses. Apple has already made commitments to stay in the country.

Although the Irish government has since moved to close some loopholes, for many years Apple was able to funnel billions in international revenue and pay minimal taxes. In 2014, the iPhone maker paid just 0.005 percent on its European profits, a minute fraction of Ireland's standard corporate tax rate.

While it's uncertain if the new Treasury guidance will impact Apple, a spokesperson for the agency specifically mentioned wanting to counter credits companies might claim after state aid investigations.