Apple Inc. (NASDAQ: AAPL) is the biggest company in the world, and it is the world’s most profitable company. Despite ending its most recent quarter with $193 billion or so in cash and cash equivalents, even the mighty Apple is having a harder time than you might imagine in living up to the new $200 billion capital return plan for shareholders.

The problem that Apple has is the same as most major U.S. companies: they simply cannot access much of their cash without facing the 35% tax that would come with repatriating the cash. To show just how international this company has become: Apple’s most recent earnings report said that international sales accounted for 69% of the quarter’s revenue — and that was based on $58 billion in revenues. In short, some $40 billion of the sales, and all of the profits from those sales, are out of reach from Apple’s management.

While we do not have a formal number on how much of Apple’s vast cash hoard is in the United States, as much as 90% may be held outside of the country. That means that another debt offering will help buffer cash needs inside the United States without having tax inefficiencies by repatriating tens of billions of dollars back from overseas.

So, Apple is undergoing a $6 billion or so bond offering to assist it in using its cash to return to shareholders. The “Use of Proceeds” section of the report said that Apple intends to use the net proceeds from sales of the notes for general corporate purposes, including repurchases of its own common stock and payment of dividends under the company’s recently expanded program to return capital to shareholders.

Apple further said that the capital could be used for funding for working capital, capital expenditures and acquisitions and repayment of debt. Just make no mistake, this capital is used as a buffer against its domestic cash as the bulk of the cash is held outside the United States.

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Standard & Poor’s assigned a AA+ rating to Apple’s unsecured shelf. Apple’s maturity schedule is as follows:

• 2017 Floating Rate Note
• 2020 Floating Rate Note
• 2017 Fixed Rate Note
• 2020 Fixed Rate Note
• 2022 Fixed Rate Note
• 2025 Fixed Rate Note
• 2045 Fixed Rate Note

As far as Apple’s expanded capital plan, the company recently authorized an increase of more than 50% to its program to return capital to shareholders. Apple said that it will now use a total of $200 billion to return to shareholders by the end of March 2017.

The company increased its share repurchase authorization to $140 billion from the $90 billion level announced last year. Apple also said that it expects to continue to net-share-settle vesting restricted stock units.

The key part for income investors in the capital return plan program was the 11% payout increase in the quarterly dividend. We viewed the new $0.52 per share dividend as somewhat of a disappointment, but much of that is because Apple’s capital is locked up overseas.

Since August 2012, Apple has returned over $112 billion to shareholders, including $80 billion in share repurchases.

Investors are not treating this note offering as anything out of the ordinary. Apple shares were down 0.5% at $125.15 on Wednesday morning. Its 52-week range is $82.90 to $134.54, and Apple has a consensus price target of $148.05.

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