COMPANY PRAISES PROPOSED ACCOUNTING RULES FOR FOREIGN SUBS.

We at Apple Computer, Inc. applaud your office's recent release of Proposed Regulations under sections 952 and 964 that would significantly reduce the burden of computing earnings and profits (E&P) of foreign subsidiaries that is now shouldered by U.S.-based multinational corporations. Eliminating the need to compute adjustments with respect to the uniform capitalization rules of section 263A and the difference between U.S. GAAP depreciation and U.S. tax depreciation will save many hours of work in many companies, including Apple, with no negative impact on government revenues. We urge you to consider extending the concept of eliminating differences between U.S. GAAP and E&P to the other items listed in Part V of the Tax Executive Institute's letter of March 27, 1991 to the Commissioner on this subject. The work involved in creating an additional income statement under a completely different set of rules for limited tax purposes is inherently unproductive, adding no value to any company's products or services. Where such efforts do not materially impact government revenues, they should be eliminated. Thank you again for moving the tax law in a positive direction.

Sincerely yours