“The U.S. Internal Revenue Service lumps in the foreign dividend with corporate income. While the U.S. offers a credit for foreign taxes paid, U.S. multinationals typically face an extra tax bill when the foreign earnings come home for a number of reasons, including the higher U.S. corporate income tax rates. So when Apple says it intends to give $100-billion back to shareholders by the end of 2015, it’s all well and good. It’s got just $45-billion in the U.S., however, and that’s what leads to a cash-rich company borrowing more cash, just to give it away.”
https://secure.globeadvisor.com/servlet/ArticleNews/story/gam/20130509/GIVOX0508ATL
