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Because it wasn't earned overseas in the way you're suggesting. It was "earned" overseas. Often companies route sales through overseas shell companies. See the StarBucks debacle in the UK. Microsoft's explanation of them being a "global" company is BS. They will wait for a corporate tax holiday to bring it back at a much reduced rate, or a chunk of it at almost no rate.

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> It was "earned" overseas.

I work for Microsoft in Beijing doing R&D; I disagree and am kind of offended by your assessment.

what about all the copies of windows in use in non-US countries? Those arent considered global?

Right, and do you need to create a company in Ireland to sell copies of Windows in France? The money is most certainly funnelled into a select few "companies" set-up in very specific countries. This is classic big business accounting and perfectly legal. It's also utter BS to spin it any other way than trying to avoid paying taxes on the money.

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