That might not be the right way to look at it. The question really is if Apple repatriated these profits, how much of it would they be willing to shower on the stockholders? Surely not all of it. Just a wild guess, say they are prepared to declare a onetime dividend of $100B. With 5.35B shares outstanding, that comes out to $19/share. Alternatively, they could double their annual dividend and pay that much out over 7-8 years.
Sure, that kind of possibility is part of what I'm contemplating (and expecting that someone else would contemplate) when trying to assess the per-share value of a tax holiday.
But I think that kind of huge one-time dividend is very unlikely. We could possibly see a one-time dividend, but if we do I wouldn't expect it to be that large. If Apple had just been sitting on its cash pile, letting it grow at the incredible rate it would have been growing at, and waiting for a tax holiday then... yes, perhaps it might do something like that. But Apple hasn't been doing that. It has, in effect, been returning much of that capital to shareholders for 4 plus years. It's just used debt (in place of its unremitted foreign earnings) to facilitate part of that capital return.
Apple has returned to shareholders more or less all of its profits over the last 17 quarters. Because of that, its cash (and equivalents and marketable securities) net of debt hasn't grown in the way that it would have and total shareholder equity hasn't grown much at all. (To be clear, cash net of debt has grown some - by about $50 billion over those 17 quarters - even while Apple returned to shareholders an amount in excess of all of its profits; there are a number of reasons for that, e.g., accounting for share-based compensation and deferred income taxes.)
So I don't see Apple dramatically increasing the scale of its capital return program in response to the kind of tax holiday we're talking about - e.g., by declaring a one-time dividend of $100 billion. I do, of course, see Apple continuing to expand its capital return program each year as it has been doing. It would do that even without a tax holiday. It likely would just stop using debt (or use less debt) to finance its capital return activities. It might also change the form of some of that capital return, and as I suggested increase its total amount some (over what it would be without a tax holiday) - just not nearly as much as you are suggesting. Again, already returning capital to shareholders at more or less the same rate it is making money (i.e. in an amount as large as its net earnings), there isn't much room to increase that rate. I think it's going to want to keep a substantial cash pile (net of debt) to allow itself flexibility going forward, not draw that cash pile down by $100 billion plus - at least not quickly.
But even if it did do something like declare a one-time dividend totaling $100 billion, that wouldn't represent a $20 (or so) per-share value increase for shareholders. To the extent the market isn't fully valuing Apple's cash holdings, it would represent some added value. But the market surely isn't valuing Apple's cash holdings at zero. In other words, whatever the market thinks a share of AAPL is worth today, it wouldn't - with no other changes - think that a share of AAPL was worth that same amount tomorrow if those cash holdings (net of debt) completely disappeared. They are worth something, even if they are sitting on the books with no clear plan for their use over the next few years. And paying a $100 billion one-time dividend, while it would put $20 (or so) per share (pre-tax) in the pockets of Apple shareholders, would come at the cost of reducing Apple's cash holdings by $100 billion. The disparity between that amount and how the market is effectively valuing that $100 billion on Apple's books is how much value such a one-time dividend would represent for Apple shareholders.
I think that a tax holiday (with a rate of, say, 10%) would add meaningful value to Apple equity. But I don't think it would be worth $20 or more per share. As a starting point it would save Apple around $50 billion in potential U.S. tax liability. Apple hasn't remitted about $230 billion in foreign earnings and estimates that it would owe around $70 billion in taxes (part of which is already accounted for, part of which isn't) on those earnings if it remitted them. At 10% Apple would only owe about $23 billion (even if it remitted all of them). But that $50 billion bump would be a one time thing. That is, of course, unless the U.S. did away with extraterritorial taxation going forward. (Could we possibly be so luck as to get that one aspect of our tax policies right?).
Anyway... the TL;DR: Yes, if not (re)patriating foreign earnings were currently holding Apple back from returning large amounts of capital to shareholders, then there might be significant shareholder value (assuming the market generally undervalues Apple's retained capital) in Apple being able to (re)patriate those as-yet unremitted earnings at a significantly reduced rate. However, not being able to (re)patriate those earnings doesn't seem to be holding Apple back from returning large amounts of capital to shareholders. It's doing that already and I don't think it would want to do it on a substantially larger scale even if it could (re)patriate those foreign earnings at a more attractive tax rate. I think it's returning capital (and will continue to return capital) at more or less the rate it thinks is appropriate anyway.
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Yes, I suppose you are right. I was mostly being snooty since the Chief thinks it's OK for some to evade taxes, but not for all. I'm far from a tax expert... wouldn't they want to have their funds in other places when the tax holiday is over?
Yes, Apple will always need capital to use in other countries. And it might not return all of its as-yet unremitted foreign earnings if there were a tax holiday. But I think it would return much of those earnings.
It would still be able to use that money in foreign countries even if it were 'returned' to the U.S. as we are referring to it now. It's just that more options for the use of that money would be opened up by having thusly 'returned' those earnings. Returning that money isn't really about moving the money geographically. It's really about foreign subsidiaries that Apple owns remitting those profits to the parent company rather than retaining those profits for themselves. The money can be held wherever and in various forms. But as it is, in effect the foreign subsidiaries haven't (at Apple's direction) said to Apple - here, we've made all this money, and now we are going to give it to you so that you, the parent company, can be said to have made it. Doing that would make Apple liable to pay U.S. taxes on those earnings even though they were (rightfully) made outside of the United States. Not doing that limits what Apple can do with that money. It can still use it in some ways - e.g., to expand operations in foreign nations. So if the effective tax rate for remitting that money to the parent company were low enough, it would make sense for Apple (rather, for its foreign subsidiaries) to remit most of it so that Apple would have more flexibility in how it could use that money.