Apple is really just the worst offender on this crap. And they want a repatriation tax discount/holiday so that their behavior will go almost completely unpunished. What we should do is state that US companies holding money overseas pay a 5% surtax on any profits not repatriated within 1 year, and no discounts for bringing it back. Make it more expensive for them to keep their profits sheltered abroad. Now this may mean more cooking the books to hide money, but at some point that becomes illegal and even if it isn't it would hurt share prices.