What exactly counts as repatriating income? Could a foreign subsidary buy shares of the US entity (akin to a buyback) instead of putting money into the US entity's treasury?

Not that I'm a fan of playing games with the market cap rather than rewarding owners...

Edit: apparently the IRS did not take kindly to IBM doing exactly this: https://seekingalpha.com/article/893331-how-microsoft-can-fr...