[djrogers]

> They can freely move it to banks in the US or to anywhere else they need it, it's only "overseas" in the sense that they recognized the revenue elsewhere

Yes, they could, however the point made above is valid - if they did that, they'd have to pay a chink of US corporate tax on it, and unless they have a use for it in the US, that'd be analogous to throwing money away.

In recent years, Apple has been taking out big loans in the US (or selling bods - same effect) collateralized by their overseas cash equivalents whenever they need an infusion of USD. Paying 2% interest is much cheaper than paying 10-15x that in taxes.