There is no "overseas cash". This cash is only overseas on accounting ledgers.
Because interest rates are currently low, the "arms length" interest rate a company can charge itself for a loan is greatly reduced.
Low interest rates have merely reduced the benefit provided by this tax avoidance scheme, bringing a company's effective tax rate back closer to their actual tax rate.
We've run out of other people's Social Security taxes needed to subsidize our low income tax rates.
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