The thinly veiled subtext is that the place they are required to pay it is nowhere.
This lawyer also has one of the worst success records in these types of cases.
https://www.wsj.com/articles/apple-to-pay-38-billion-in-repa...
> A provision allows for a one-time repatriation of corporate cash held abroad at a lower tax rate than what would have been paid under the previous tax plan.
https://www.nytimes.com/2018/01/17/technology/apple-tax-bill...
You're free to argue that 15% is not a high enough corporate tax rate, but it is factually incorrect to say Apple did not pay US tax on the money they earned overseas.
No, that is decidedly not what we are talking about. The claim was that holding all your money away from the US does not matter because the tax will be paid eventually. As we see, no it wasn't and the tax rate was not lowered because "taxes change over time" but because otherwise companies will just not ever repatriate their money.
It is factually correct to say that apple did not pay the full US tax rate on the money they earned overseas. You are free to argue that this is fine and they at least still paid some, lower tax rate, but this is the whole topic we are talking about. Apple pays very low tax rates and the EU, Ireland and the US are arguing whether this is unfair (state aid) and should change.
A temporary change in the tax rate during 2018 is, by definition, the tax rate changing over time. If a product normally sells for $50 and I wait until it's on sale for $25 to buy it, did I pay the "wrong" price? No, I paid the price the vendor set at the time of purchase.