[mpat]

"As of September 24, 2011 and September 25, 2010, $54.3 billion and $30.8 billion, respectively, of the Company’s cash, cash equivalents and marketable securities were held by foreign subsidiaries and are generally based in U.S. dollar-denominated holdings. Amounts held by foreign subsidiaries are generally subject to U.S. income taxation on repatriation to the U.S."

http://files.shareholder.com/downloads/AAPL/1826229879x0xS11...

These tactics don't exempt corporations from US federal taxation, they just serve to delay when the taxes are payable. Apple owes US federal income taxes on the earnings of its foreign subsidiaries that is payable upon repatriation of the cash to the US. Accordingly, Apple and has booked an $8.9 billion liability for the taxes it owes on the unremitted earnings of foreign subsidiaries. Unless Congress moves forward with a "repatriation holiday," that liability will remain until Apple brings back the cash to the US to fund domestic investment or to return to shareholders and pays the US taxes it owes.