Looks like that was a one-time deal for IBM...
The Internal Revenue Service moved to shut a corporate tax loophole last week, just two days after International Business Machines Corp. used it to save an estimated $1.6 billion, according to a person familiar with the transaction.
On May 29, IBM said it had structured a $12.5 billion stock repurchase to take advantage of funds it earned overseas without making them subject to U.S. corporate tax rates. Tax attorneys call such deals "Killer B" transactions because they are designed to circumvent IRS section 367 B covering U.S. taxes on repatriated earnings.
On May 31, the IRS announced plans to issue regulations making companies pay U.S. taxes when they buy back their stock, even if the shares are purchased by an international subsidiary. It said the planned ban on the practice would take effect that day, even though the regulations won't be finalized for some time.
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