> They can freely move it to banks in the US or to anywhere else they need it, it's only "overseas" in the sense that they recognized the revenue elsewhere

Yes, they could, however the point made above is valid - if they did that, they'd have to pay a chink of US corporate tax on it, and unless they have a use for it in the US, that'd be analogous to throwing money away.

In recent years, Apple has been taking out big loans in the US (or selling bods - same effect) collateralized by their overseas cash equivalents whenever they need an infusion of USD. Paying 2% interest is much cheaper than paying 10-15x that in taxes.

At which point, at what level do you operate your own bank? These are gargantuan holdings.

I mean, they basically do operate their own bank and a significant size lending operation.

Citizens Bank does the lending for Apple Upgrade Program, and Goldman Sachs does the lending for Apple credit card.

Technically, a bank has a lot of rules to follow, and I do not think they want to get into that business (yet).

I haven’t used Apple Card, but it was apparent when I financed with their previous partner Barclays that they had their own say at least in the application and approval process. It was wildly different from applying for credit in any other scenario I’ve experienced. They’re clearly backed by other credit vendors but that doesn’t mean they’re not operating their own financial institution.

> They can freely move it to banks in the US or to anywhere else they need it

But then they'd have a massive tax bill.