Jacket Boys' Spyder Softshell Big Racing Red U.S. companies are holding more than $2.6 trillion in profits across the globe and they haven't paid U.S. taxes on it. Why is so much money offshore, and how could the tax code be changed to bring it back? WSJ's tax reporter Richard Rubin dives in. Photo: Heather Seidel/The Wall Street Journal

For Apple Inc., bringing billions of overseas earnings home is one thing. Keeping it there is quite another.

Such is the conundrum facing the world’s most valuable company, which also happens to the world’s largest design studio. Apple makes nothing in the most traditional sense. The company farms out the labor-intensive manufacturing of its best-selling devices to production partners worldwide—though mostly in China. This still isn’t cheap. Apple had nearly $15 billion in capital expenditures in the fiscal year ended September,...

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