I would assume that foreign taxes have already been paid on accumulated profits. It would be a stretch, IMO, to assume that all of those taxes get a full offset, but perhaps is the case. But the 35% repatriation tax is sufficient to keep most all of those corporate earnings off shore. I think that it is just a matter of time before the government gets the message and makes adjustments such that the cash can come home to the USA where it can be put to use helping our workers and our economy. But for now the behind the scenes discussion continues, with Apple and other multinationals keeping up intense pressure on D.C. to make a constructive change.
"U.S. companies now owe U.S. taxes on all their profits.
They can claim credits for taxes paid to foreign governments and
defer U.S. taxation until they repatriate the money.
The administration wants to retain that “worldwide” tax
system. The administration proposal would make it harder for
companies to defer income. In addition, the new framework
announced yesterday mentions adding a minimum tax on global
income, without providing details on how the tax would work."
"...........the Obama administration proposed a long-awaited cut in the top rate of U.S. corporate tax
from 35 per cent to 28 per cent. But the White House also disclosed
something more contentious. The administration is suggesting U.S.
companies’ foreign earnings should be subject to a “minimum tax”.
The current system for taxing earnings of foreign subsidiaries
controlled by U.S. companies is controversial and counterproductive.
Such foreign earnings are theoretically taxed at a 35 per cent rate if
brought back to the U.S., but not taxed at all by the U.S. as long as
these earnings are kept abroad.