I think there is a difference between saying 'we comply with the law' and being happy when someone retrospectively changes the law and then demands n years payments under the new rules.
Apple's structures are a correct reading of international tax rules. The rules should be changed; Apple should not be punished for following the law.
If Apple asked for the state of Texas for a tax cut in the state of New York and then got fined for not paying their taxes you wouldn't call name it "retrospectively".