In an interview with Irish public broadcaster RTÉ, Apple CEO Tim Cook said Thursday that the company planned on bringing billions of dollars held overseas back to the United States to be subject to American taxes.

"We provisioned several billion dollars for the US for payment as soon as we repatriate it, and right now I would forecast that repatriation to occur next year," Cook said.

The interview came two days after the European Commission ordered Ireland to collect €13 billion (£11.1 billion/$14.5 billion) in back taxes from Apple after the company benefitted from years of a sweetheart deal and dubious, but legal, tax shenanigans.

However, what Cook didn’t explicitly say is that Apple likely would only do this if Congress passes a new so-called "tax holiday," which the Obama administration has proposed as part of the government’s Fiscal Year 2017 federal budget.

In February 2016, the Department of Treasury announced that the White House would like to "impose a one-time transition toll charge of 14 percent on untaxed foreign earnings that US companies have accumulated overseas. The earnings subject to the one-time tax could then be repatriated without any further US tax."

As The Wall Street Journal reported, American companies are believed to be holding approximately $2 trillion in cash overseas that is shielded from US taxes. Under American law, companies must pay a 35-percent corporate tax rate on global profits when that money is brought home—so there is an incentive to keep as much of that money overseas as possible.

In October 2015, Ars reported that Apple pays an effective 2.3-percent tax rate on overseas profits. Google, Microsoft, and many other large multinational corporations engage in similar behavior.

Fat chance

Unfortunately for Cook and Apple, at least one tax law expert told Ars that this tax holiday proposal is unlikely to take effect.

"I don’t think it is likely in an election year," Omri Marian, a professor at the University of California, Irvine, told Ars by e-mail. "However, if the [European Commission] decision holds, it is certainly more likely to gain favor with lawmakers after the election. The US would very much like to tax foreign earnings of US multinational before the EU does."

Absent making nice with government institutions, there’s not a big incentive for Apple or other companies to bring money home at this time.

"For the most part, companies like Apple don't need to repatriate money," Samuel Brunson, a tax law professor at Loyola University Chicago, e-mailed Ars. "They're sitting on plenty of cash here, and if they don't have enough, they can usually borrow it from their offshore subs (or a bank or whomever). In fact, to the extent they can deduct interest payments, borrowing from a related entity may be advantageous for tax purposes."

Brunson explained that such debt "may not look as good for financial accounting purposes," but it makes sense for a company like Apple. "Aside from those kinds of considerations, they can sit on their money offshore pretty much as long as they want," he concluded.

In the RTÉ interview, Cook said that in 2014, Apple paid an effective global rate of 26.1 percent, which he described as "reasonable."

"When you’re accused of doing something that is so foreign to your values it brings out an outrage in you and that’s how we feel," he said. "Apple has always been about doing the right thing, never the easy thing. We haven’t done anything wrong and the Irish government hasn’t done anything wrong."