> they are lending the cash to the US entity to execute but backs I'm pretty sure they don't do this as a loan from the untaxed or under-taxed overseas entity

> they are lending the cash to the US entity to execute but backs I'm pretty sure they don't do this as a loan from the untaxed or under-taxed overseas entity back to the taxed parent would create a tax event. AAPL has more cash than it knows what to do with, but it's a huge borrower in the corporate market so that it can fund its dividend payments.