Dr. Jim Stewart:

That depends. For example, the country where the intellectual property, IP, was created, that is, America, has transferred the rights to those assets to Cork and the value is located in Cork. One might dispute the price that Cork subsidiaries paid for that but that is a different issue. The rights are located in Cork and that is where the intellectual property is held and where the profits are located.

Those who know far more about tax than I would say it is plausible to repatriate profits to the US under current legislation without triggering a tax charge of anywhere near 35%. The problem is it is difficult to get in very large sums. If one were trying to get in a couple of billion dollars, one would be hit but by nothing like 35%. That is why Apple has engaged in various alternative tax strategies.