The U.S. government is asking a federal court to enforce an IRS summons to Apple for user data, that will be used in a Swiss tax investigation. The defendant isn't pleased.

Federal prosecutors want a California judge to reject a petition aiming to block the Internal Revenue Service from demanding Apple turn over account records linked to Cristian Caruso. He holds Swiss and Italian citizenship and is under investigation for possible Swiss tax liabilities.

Caruso filed in the U.S. District Court for the Northern District of California to stop the summons. The IRS is seeking records from Apple's headquarters in Cupertino. They include subscriber names and addresses, session times, connection records, payment methods, and IP addresses spanning 2016 to 2023.

Officials maintain the request follows the , which allows both governments to share tax information for enforcing their own laws. The IRS says it issued the summons in response to a request from Swiss tax authorities.

Arguments over the IRS demand

Caruso claims the summons is too broad and amounts to a fishing expedition. He argues the requested data has little to do with calculating Swiss tax liabilities and points out that he lived in the United Kingdom for part of the period in question.

His petition leans on the treaty's standard of "foreseeable relevance," which calls for requests to be specific and justified. He says the IRS needs to show the information is necessary and cannot be found elsewhere.

U.S. courts generally reject demands that lack a clear and targeted purpose. Caruso to apply that standard here.

Government's view of treaty obligations

Federal prosecutors argue the summons meets both U.S. legal requirements and the treaty's terms. They say the IRS is simply helping Swiss authorities confirm Caruso's potential liabilities and that the treaty permits sharing data held by U.S. companies.

Apple has no formal role in the dispute other than complying if the court approves the summons.

Governments increasingly rely on companies like Apple to provide detailed digital records for cross-border tax enforcement. Metadata, payment details, and account connections can help identify undeclared income and offshore assets that would otherwise stay hidden.

Privacy advocates raise concerns about broad requests for user data. Sweeping up large amounts of personal information can intrude on privacy rights and may exceed what is necessary for a legitimate investigation.

Balancing the need to enforce tax laws with the obligation to protect user data has become an ongoing legal challenge.

Tax authorities around the world have tightened cooperation in response to high-profile evasion scandals and the growth of hidden offshore accounts. Treaties like the U.S.-Switzerland agreement aim to promote transparency and allow governments to track down unpaid taxes across borders.

Efforts to strengthen tax enforcement have put tech companies at the center of these investigations. Data they hold can offer crucial evidence, but their involvement also brings questions about user privacy and the appropriate scope of government power.

A ruling in favor of the government would force Apple to hand over the records, which the IRS would then share with Swiss tax officials. A decision for Caruso could narrow how broadly the IRS can use such summonses and clarify the limits of information-sharing under the treaty.

Judges will need to weigh treaty obligations, IRS enforcement authority, and privacy protections. They will decide how far the government can go when requesting data from major technology firms.