There are significant tax risks that Dell top management is aware of but chose to cover up. They aren't merely tax planning. Some are downright tax evasion. Some straddle the line between tax evasion and tax avoidance.
All are being covered up. Tom V and his team of so-called "tax professionals" are charlatans and fraudsters.
This is an anonymous forum and I should be able to share the details without repercussions but I'm afraid to do so nonetheless. So I cannot share anything more beyond general statements.