Michael Dell's plan to take his computer company Dell Inc. private may hinge in part on whether he's able to exploit one of the company's most valuable assets: as much as $14.2 billion of cash and bonds outside the U.S.

Like many of the world's largest technology companies, Dell has legally avoided billions of dollars in income taxes by attributing profits to overseas subsidiaries in tax havens. Bringing the cash back to the U.S. to finance the buyout would risk subjecting the money to the 35 percent corporate income tax rate, with a credit for any foreign income tax they've already paid.

"You can be sure the buyout team is looking at the most effective way that asset can be used. They're spending hours and hours on this," said Antony Page, a professor at Indiana University's Robert H. McKinney School of Law and a former mergers and acquisitions lawyer. "There may be loopholes in there that sophisticated tax lawyers can find that aren't immediately obvious."