A Swiss tax investigation has triggered a legal fight in the United States over access to Apple user data. Federal prosecutors have asked a California court to enforce an IRS summons. The order seeks account information linked to Cristian Caruso, a dual Swiss-Italian citizen.
The IRS issued the summons under the U.S.–Switzerland tax treaty. This agreement allows both countries to share financial data for tax enforcement. The request includes subscriber names, addresses, session logs, payment methods, and IP addresses from 2016 to 2023.
Caruso Argues Summons Is Too Broad
Caruso, the subject of the probe, filed a lawsuit to block the summons. He claims the IRS request is too broad and amounts to a “fishing expedition.” His legal team says the data has little relevance to Swiss tax liabilities. They also note that Caruso lived in the United Kingdom for part of the time in question.
Under the treaty, requests must meet the “foreseeable relevance” standard. This means they must be specific and justified. Caruso argues the IRS has not proven that the information is necessary or cannot be found elsewhere.
Privacy Concerns and Global Enforcement
The case reflects a growing trend. Tax authorities worldwide now rely on tech companies to track hidden income and offshore accounts. Digital records, including payment details and metadata, provide key evidence. However, sweeping data demands raise privacy concerns and risk overreach.
Prosecutors maintain that the summons meets legal standards and treaty terms. Apple’s role is limited to compliance if the court approves the order.
A Decision With Global Impact
The outcome could set an important precedent. A ruling for Caruso may restrict how broadly the IRS can respond to foreign requests. A win for the government could strengthen cross-border cooperation but also deepen privacy debates.
