[toomuchtodo]

Building something is hard. Writing a check is easy. Apple could easily make the payout contingent on a smooth integration. Apple could even have a foreign subsidiary purchase Dropbox, thereby allowing for full use of its external profits it hasn't brought back to the US due to taxes.

That's the benefit of cash. It solves almost every problem.

[gamblor956]

They have rules to prevent this. See IRC Section 956. In essence, the use of a foreign sub to acquire a US company would be treated as a deemed dividend back to Apple.

[toomuchtodo]

Today I learned! Thank you for sharing!

[jalonso510]

I'm not a tax expert, but I think dropbox would have to be a foreign company in order for them to purchase it with foreign cash and avoid tax problems.

[ascagnel_]

Apple would effectively be shifting the tax burden onto Dropbox, since it would be up to Dropbox to repatriate the funds.