The cash we generate outside the U.S. is principally to be used to fund our international development. If the funds generated by our U.S. business are not sufficient to meet our need for cash in the U.S., we may need to repatriate a portion of our future international earnings to the U.S. Such international earnings would be subject to U.S. tax which could cause our worldwide effective tax rate to increase.
Or rather, Ritchie quoting Kelloggs. And entirely failing to note that this entirely explodes his main thesis. No one does “avoid” corporation tax through their various machinations. They delay it until such time as they repatriate the profits. In the interim they invest it back into the business (there is no other place for it to go, it must either be invested or handed out to shareholders).
Ritchie complains that companies do not invest enough. Yet Ritchie complains when companies don’t pay out to shareholders but invest.