San Jose, California–based eBay Inc. has substantial revenue flows in myriad regions and currencies around the globe. "eBay has some presence in a large proportion of the world's countries," says Dmitry Martynov, director of foreign exchange (FX) and corporate finance. "We have long operated in China, India, Korea, South Africa, and many others."

Historically, eBay built up significant currency reserves in some of these jurisdictions. "We have long had an imbalance, where we generate 60 percent to 70 percent of our cash overseas but spend the bulk of our free cash flow in the United States," Martynov explains. "Before the U.S. tax reform in late 2017, bringing back our overseas cash was not the most economical decision. The Tax Cuts and Jobs Act allowed eBay Inc. to receive future offshore distributions without U.S. taxation."

Thanks to the law, the company's international subsidiaries were able to distribute excess offshore cash—funds above what they needed locally—to eBay Inc. In some markets, though, distributing excess cash was easier said than done.