What I'm talking about is the process after the profit has been booked and is held in a foreign account. What you describe is how to profit ends up in one of th

What I'm talking about is the process after the profit has been booked and is held in a foreign account. What you describe is how to profit ends up in one of those foreign accounts. There are certain rules for US controlled companies about what they can and cannot do with the money held in those tax deferred subsidiaries. But if a US company is not US controlled (e.g. a corporate group with a holding company not based in the US) these (anti avoidance) rules do not always apply or are applied differently. Second, if you have an EU company acquiring a US domestic entity, they will generally be able to save more on taxes due to the high corporate tax rate. In its simplest form: say an entity that is taxable at 20% acquires a business paying 35%, they'll be able to convert a significant portion of that 35% by legally stripping earnings in various ways (loans, consulting agreements, ip license agreements, etc). See https://en.wikipedia.org/wiki/Tax_inversion https://en.wikipedia.org/wiki/Tax_inversion