The classic offshore approach is that Apple USA doesn't make any profit because they find a way to make the accounting work such that Apple Ireland actually mad

The classic offshore approach is that Apple USA doesn't make any profit because they find a way to make the accounting work such that Apple Ireland actually made the profit. It only becomes income or dividends when it gets transferred back to the USA. An example might be to assign the patent ownership for the new M1 chips to the Ireland subsidiary. Sell them for $1. Then charge the USA based firm $1 billion in licensing costs. Make $1 billion in income selling the chips. Boom $0 profit. Except now there is massive profit in the Ireland subsidiary, which can pay very low taxes. The problem is that the money is stuck there. If they give it back the parent company as a dividend, then that is income to the parent.