[clarky07]

There's very little reason to. unless they were just desperate to use the cash why pay more taxes than they need to? The money wasn't made in America, they don't have a great claim to it (many countries don't have this tax we are talking about).

In the past, we've had tax holidays were they made it a bit cheaper, seems sensible to wait and hope it happens again.

Alternately, they could buy companies overseas. It's obviously going to be hard to invest that much money, but if they can find interesting options it'd be a much better use of the money than paying a really high tax.