Over the last few years foreign earnings of U.S. companies, especially those retained oversees as indefinitely reinvested earnings, have been in the news. Last year, Apple, Inc. made news by choosing to raise $17 billion by selling bonds instead of repatriating earnings held offshore. Previously, decisions by Microsoft and Hewlett-Packard had been discussed. Now, Caterpillar’s “tax strategy” is under examination. The reason for this attention is due to the continuously growing amount of Foreign Indefinitely Reinvested Earnings (IRE), which is not taxed under the U.S. tax code.