Forbes:

Corporate M&A decisions are increasingly being driven by offshore tax policy. It’s hard to argue the business logic of using offshore income to acquire foreign companies versus bringing the money back into the U.S. for a domestic acquisition.

Following the rough tax math of a foreign acquisition, Apple’s $3.2 billion bid would really be more like $2 billion if the transaction could take place in Ireland. Considering the fact that Apple currently has approximately $54 billion in cash parked offshore, the benefits of doing a foreign acquisition over repatriating that cash back into the U.S. become even more apparent.

Interesting conjecture.