I used to wonder why do companies with ample surplus cash still take debt? The corporate finance rationale of opportunistically benefiting from mispricing in debt markets, do not apply to companies which generate ample free cash flow, and which do not indulge in trading/proprietary investments. Hence I decided to analyze some companies for more light on this subject.
What is common between Apple, Microsoft and Qualcomm? Each of them have sizable cash and cash equivalents held in foreign subsidiaries, which would be subject to USA taxes of upto 35%, if repatriated via dividends. Indeed, those companies had escaped USA taxation(at global level) on the earnings of their foreign subsidiaries, by declaring that they had a permanent intention to keep those earnings offshore. So what does it mean for shareholders of those companies? Microsoft admits in its 10K that Of the cash, cash equivalents, and short-term investments at June 30, 2011, approximately $45 billion was held by our foreign subsidiaries and were subject to material repatriation tax effects. .....As of June 30, 2011, approximately 68% of the short-term investments held by our foreign subsidiaries were invested in U.S. government and agency securities, approximately 12% were invested in corporate notes and bonds of U.S. companies, and 5% were invested in U.S. mortgage-backed securities, all of which are denominated in U.S. dollars.
- Companies may find it more rational to borrow money for paying their dividends, instead of bringing the cash back.
- Companies may find foreign acquisitions more attractive, to utilize their trapped cash.
- While expropriation risk is minimal since companies would not risk certain jurisdictions, the host country may be tempted to balance its budgets by the levy of witholding tax to ensure that earnings do not escape its juridiction. Hence, a CASH TRAP is quite likely.
- Reduced liquidity domestically:- As Qualcomm states in its 10K Our cash, cash equivalents and marketable securities at September 25, 2011 consisted of $5.7 billion held domestically and $15.2 billion held by foreign subsidiaries. Of the amount of cash, cash equivalents and marketable securities held by our foreign subsidiaries at September 25, 2011, $13.5 billion would be subject to material tax effects if repatriated. Due to tax and accounting considerations, we derive liquidity for operations primarily from domestic cash flow and investments held domestically.