If you have tons of cash from overseas revenues that you have sitting in your offshore subsidiaries that you don't want to pay domestic taxes on, and you can us

If you have tons of cash from overseas revenues that you have sitting in your offshore subsidiaries that you don't want to pay domestic taxes on, and you can use that overseas cash as collateral for low-interest loans domestically, and you believe corporate taxes on overseas earnings brought onshore will likely be lower in the future, then it makes sense to pay dividends and buy back shares using onshore loans against offshore holdings. Though, for buybacks, I wonder why the overseas subsidiary doesn't buy shares of the domestic parent. Perhaps that tax loophole has already been plugged.