Tax makes companies do strange things. And at first glance few seem stranger than Apple’s decision to borrow $17bn to fund, in part, a $60bn special dividend. This should be unnecessary. The technology company is one of America’s most liquid companies. Its cash pile – worth about $145bn – easily covers even the huge payout it is proposing.

Borrowing billions makes sense in one respect, however. It saves Apple from writing a fat tax cheque to bring that cash back from overseas, where it currently resides. That this should be so speaks volumes about the US tax code and the invitation it extends to legal tax avoidance through its differing treatment of foreign-source and domestic earnings.

Kinks in the rules introduced in the 1990s make it easy for multinationals such as Apple to pile up lightly taxed foreign profits outside the US. There they sit beyond the reach of the taxman until the group repatriates them. In Apple’s case, it holds roughly $100bn overseas in this way.