In this particular case, it seems obvious that a warrant is inapplicable, since US law enforcement officers don't have the authority to seize Microsoft-controlled data located on servers in Ireland. If Microsoft had instead been served with a subpoena, they would be required to hand over any documents that they had access to, regardless of the data's physical location. However, there are strategic advantages (for law enforcement) to favor warrants, since they're much harder to challenge, and that treaty obligations with foreign countries might restrict the kinds of data that can be retrieved from overseas servers.