Yes you can. From [1]: While U.S. tax law is currently making it unattractive for Apple to spend its foreign earnings on buybacks, that pile of overseas capita

Yes you can. From [1]: While U.S. tax law is currently making it unattractive for Apple to spend its foreign earnings on buybacks, that pile of overseas capital (now above $200 billion) is effectively guaranteeing bonds that raise cheap capital Apple can use to buyback its shares at an extreme discount. Steps: 1. Loan "US" cash, guaranteed by foreign cash (doesn't need profits repatriated) 2. Use loaned cash to buyback shares Optimization: 1. Loan "US" cash, guaranteed by foreign cash 2. Buyback using loaned cash 3. Have your foreign subsidiary buy the loan from whoever you loaned from 4. Use the interest payments to transform US income into foreign (non-taxable) income (it's not quite unlimited, there's a number of problems with this) [1] http://appleinsider.com/articles/15/10/27/apple-inc-snatches-up-14-billion-of-its-own-shares-in-massive-q4-buyback-surge http://appleinsider.com/articles/15/10/27/apple-inc-snatches...