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> With Apple holding a lot of cash offshore awaiting for a favourable way to onshore it

I don't think that's relevant anymore. My understanding is that the 2017 TCJA required prior unrepatriated earnings to be recognized and taxed over eight years (so still ongoing) and future foreign earnings not subject to US tax (except if the foreign tax is below the corporate alternative minimum tax rate). As a result of those changes, there's no need to hold cash offshore.




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