repatriation

And not all those costs can be credited against US taxes on repatriation, so double taxation scenarios exist.

So, the United States treasury will be receiving more than just the repatriation tax.

If they wanted to bring $100B back, they would pay up to $35B (the use repatriation fee - minus the foreign taxes).

He's suggesting the lobbyists are in the right in this case, and the tax rates for repatriation should be lowered to something more reasonable.

Can offshore cash be used for acquisitions without being taxed on repatriation?

Liberia was formally independent, although bound to the United States by economic ties as it was founded as a repatriation site for freed slaves from America.

If that did happen, we'd be in a world war, and I'm guessing that would lower iPhone sales and nobody would much care about repatriation taxes.

And the corporations only hold out for a repatriation holiday because there has been one in the past, and there is a decent chance of there being one in the near future.

Taxing the repatriation of funds that have already been taxed (Eg: Apple sells a Mac in germany, it pays taxes on the profits in germany) is punitive and very rare for a country to do.

So all this money accumulates offshore and can't come back to the US unless some taxes are paid, which is why Tim Cook meets with Congress to try and lobby for a tax repatriation holiday.

I was hoping for a little more information on the reason Apple's foreign subsidiaries can't buy Apple stock without repatriation of funds (and whether or not this would require Apple shares to be tradeable on a foreign exchange), or what it would take for Apple to reincorporate where the money is as a way to eliminate the need to repatriate at all.

If you have money overseas that you don't want to repatriate because of tax rates (personal opinion: tax rates aren't too high for repatriation), would it not make sense to spend that money on renewables overseas for energy you're going to consume anyway?

I think I agree, but I believe you're saying "repatriation" when you mean "expropriation." Repatriation usually refers to a requirements to realize gains, etc.

This situation doesn't really seem like it's "history" in the same sense, considering it happened so recently, governments are still actively working against them as they attempt repatriation, and the TLD issue is fresh.

(2) If most of the cash is held overseas - Unless the US has a tax repatriation holiday, companies will face a "make-whole" tax bill based on the delta of the tax rate between the US and the foreign domicile.

The tax on foreign earnings usually isn't assessed until the company brings it back to the United States (you'll hear companies talk about getting hit with a repatriation tax if they bring their "trapped" offshore cash back onshore to the U.

Repatriation of those funds would essentially mean paying close to 35% tax (+ state taxes).

Repatriation is somewhat of a red herring.