Which has nothing to do with why Apple took on debt to pay dividends.
If Apple took funds from a foreign subsidiary to pay shareholder dividends it would have to pay
1) Federal Corporate income tax of 20%.
2) CA state corporate income tax of 9%.
Then out of the 73% left over, the shareholder would pay state income tax + federal dividend tax. That means the shareholder ends up keeping between 50-60% of the funds Apple paid.
If Apple borrows the funds instead, it owes no federal or state corporate tax. The shareholder just needs to pay state income tax and federal dividend taxes, so after tax they end up with 70-85% of the funds Apple paid.
