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> Because they'd have to pay taxes if they use the foreign reserves?

This is the main reason.

> Because they are somehow getting a higher interest rate return on their reserves then they'd have to pay to borrow? (That would seem pretty impossible).

This is also a possibility. Apple has extraordinarily good credit. They can consequently borrow at near-zero interest rates. They can then invest that amount of money in some (perhaps only slightly) higher risk security than their own bonds and turn a profit -- and if the money was originally held by a foreign subsidiary then so is the profit from the investment.




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