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In its December approval of the most extensive tax-code revisions since 1986, Congress scrapped the previous international tax system for corporations — an unusual arrangement that allowed companies to defer U.S. income taxes on foreign earnings until they returned the income to the U.S. That “deferral” provision led companies to stockpile an estimated US$3.1 trillion offshore.

By switching to a new system that’s designed to focus on domestic economic activity, congressional tax writers also imposed a two-tiered levy on that accumulated foreign income: Cash will be taxed at 15.5 per cent, less liquid assets at 8 per cent. Companies can pay over eight years.

Apple has the largest offshore cash reserves of any U.S. company, with about US$252 billion at the end of September, the most recently reported fiscal quarter. The tax rate indicates that Apple is likely bringing back a majority of its overseas cash back to the U.S., leaving only a small portion for international investments like retail stores.

“They’re going to have well over US$200 billion by the end of this year that will be available for incremental investments, capital returns and M&A,” said Matthew Kanterman, a New York-based Bloomberg Intelligence analyst. The new tax law lets U.S. companies bring overseas cash reserves back home in one year and pay the resulting tax bill over eight years. “And Apple hasn’t historically done big M&A,” he said.

The US$30 billion in capital expenditures will come as part of US$350 billion that Apple expects to spend in the U.S. over the next five years. The 20,000 new jobs include additional Apple employees at its campuses, data centres, and retail stores, but not third-party developers for iPhone and Mac apps, an economy Apple has touted in the past.