[radog]

This is cash that was taxed once in the foreign jurisdiction at whatever prevailing rate was in effect there. With the exception of the US, nearly all developed countries have territorial tax systems at which the rate on those foreign profits would be 0%.

A repatriation holiday would be a huge (and poorly targeted, considering nearly the entire benefit inures to about 10-20 firms) giveaway, but it's only discussed in the first place because of our strange worldwide corporate tax system.