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> The board of an American company could perfectly well choose to repatriate all foreign income, pay U.S. taxes on it, and then pay out a dividend using the repatriated income.

Considering US corporate tax rate is among the highest in the world, Apple, GM and Coca-Cola have to pay a higher repatriation tax than Samsung, Toyota or Nestle. This seems to give foreign companies a strategic advantage as far as having larger R&D budgets, flexibility to drop prices, etc.



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