In addition to the domestic cash Apple will be using to fund its dividend and stock repurchase programs, it has some $100 billion in cash overseas which it isn't about to bring home any time soon.

"Repatriating the cash from offshore would result in significant tax consequences under current U.S.law," Oppenheimer said. "We think the current tax laws provide a considerable economic disincentive to U.S. companies that would might otherwise repatriate the substantial amount of foreign cash that they have."

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