You might pay dividends to shareholders, you know like companies did in the good old days...or use it for employee compensation or lots of other things. You might not build factories, but on the other hand you might if there were some advantages to doing so (rapid prototyping, flexible manufacturing, JIT with tighter chain) a company could do the right thing every once in a while.
Sorry, no. Dividends are a way to get out from under taxes, just like the employee disbursements that this article is complaining about. I'l *maybe* do one in order to have a paper loss, and end up being able to repatriate funds without paying taxes on them. I may also do it if I'm too tasty a takeover target, and a substantial amount of stock is outstanding (in which cause, I'm more likely to have the Cayman company buy company stock, with the company's own money, instead).
If I want to build a rapid prototyping facility, I'll do it with money already in the U.S., in order to reduce my liability.
If I want to buy chips and make it look like I'm a good guy, then I'll contract with Samsung to build a chip fab in the U.S. from which I'll buy the chips (which is exactly what Apple did, in fact).
But that's beside the point, point is you're going to need to use the money somewhere (and probably not in the tax haven where you're storing it). When you eventually move the money into whatever country you are going to use it in you'll have to pay taxes on it.
No. Very few countries tax you on the differential between the tax rate where the money was earned and where the money is used. The U.S. is one of the exceptions, and with a (max) 35% corporate income tax, and a (max) 15% state income tax, if you used a double Irish on the money in the first place (20%), then you are talking paying another 30% to get to the 50% tax that they want to extract from you.
This is why repatriation is a big deal for U.S. companies -- and why they refuse to do it.