By TATIANA PROPHET

U.S. corporations have kept money earned overseas outside of the country for decades, to avoid paying taxes twice: once to the country where they earned the revenue, and once to the country they call home.

As of April 2017, the total was an unprecedented amount: $2.6 trillion, with a T. That's also T for Tim, Tim Cook. The CEO of Apple, Inc, the largest holder of cash, has acknowledged the company is keeping $231 billion in cash overseas to avoid paying the 35 percent corporate tax rate.

With the U.S. Senate's passage of sweeping tax reform, the repatriation of a portion of that $2.6 trillion is imminent. According to the Senate version of the bill, a one-time tax rate of 14.5 percent will be levied on overseas cash, while the House version calls for 14 percent. On illiquid assets, the Senate tax calls for 7.5 percent and the House version 7 percent. (A previous version of the Senate bill had 10 percent for cash overseas and 5 percent for illiquid assets). Both bill versions will have to be reconciled, with changes and compromises, before a vote that Republicans hope to hold in time for Christmas.

The amount of money being kept overseas for a rainy day amounts to 12 percent of the nation's Gross Domestic Product -- no small change.

Critics of this measure (and of lowering the corporate tax rate) say corporations may not create new jobs; they may just buy back their stock. That's what happened last time there was a "tax holiday," under George W. Bush in 2004. At that time, most of the companies who brought their cash home (for a total of $312 billion) used it to reward shareholders.

Studies showed that the corporations did not use their repatriated revenue for investment or job creation, but actually cut thousands of jobs. All things are not equal this time, however. The years immediately following the tax holiday were marked by the housing bubble, a boom before the bust that didn't involve manufacturing or infrastructure.

Apple CEO Cook did not specify what the company would do with the money, whether mergers and acquisitions or original content, but he did give hints that Apple is planning to produce original content with the Apple Music label.

So while think tanks and Twitter users shout to the heavens with their detailed knowledge of tax code and implications, and the debate rages on about whether lowering the corporate tax rate will actually help the economy, one aspect of tax reform could turn out to increase the momentum toward greater GDP growth and, at least in the short term, better jobs. As President Kennedy said when pushing for tax cuts: "a rising tide lifts all boats."

That's a little different from trickle-down economics, in that it focuses on overall economic improvement, entrepreneurialism and prosperity as a solution to the lack of opportunity we have seen for so many years.

Stay tuned.