How Apple Could Make $1 Billion for Carl Icahn If His New Super PAC Succeeds

Carl Icahn's tax repatriation super PAC might just help him get everything he's always wanted out of Apple (AAPL) .

The billionaire activist investor announced plans on Wednesday to launch his own super PAC dedicated to corporate tax reform. Starting with an initial injection of $150 million of his own capital, the group will concentrate its efforts on overhauling the U.S. tax system to keep corporations from moving headquarters and profits abroad. Should he succeed, it could mean that Apple, a major overseas cash hoarder and his second biggest investment, might bring its massive cash stockpile back to the U.S. -- and to investors. And the upside for Icahn could be enormous.

"It would be hitting the mini-lottery," said Dan Ives, managing director of Virginia-based investment bank FBR Capital Markets.

Moody's Investor Service estimates that as of December 31, 2014, 89% of Apple's $178 billion cash stash -- or $158 billion -- is parked outside the U.S. Today, that number is estimated to be about $200 billion.

Given tax rates, it's no wonder it is in no hurry to repatriate funds: according to a WalletHub study, Apple enjoyed a 4.4% international tax rate overseas in 2014, compared to the 59.4% federal tax rate it estimates the company was subject to last year.

"There is so much excess cash out there," said Andrew Chang, director of corporate ratings at Standard & Poor's. "Frankly, if there weren't such friction on repatriation issues, the overall cash balance would be much, much smaller, and that excess cash would be going back to shareholders."

If international tax reform, such as the one-time 5.25% repatriation holiday that took place in 2004 or a more long-term reduced rate (Icahn mentions 5%-to-10%), were to happen, the implications for Apple -- and its shareholders -- would be huge.

"It would be a one-two punch, because there would be an actual event in terms of a buyback, a dividend situation, but then also the stock would start to get re-weighted," Ives said.

Say the United States implements a 10% tax rate on repatriated cash (the high end of Icahn's estimate). Assuming Apple has $200 billion abroad, that means it could bring back $180 billion. Now, if Apple decides, for example, to use just half of that amount -- $90 billion -- for a one-time dividend across its 5.7 billion outstanding shares, that would mean a distribution of around $15.75 per share. For Icahn, who currently owns about 52.8 million Apple shares, it would signify a payday upwards of $830 million. If instead Apple were to use that $90 billion to buy back even more of its shares, that would increase his ownership of the company and potentially increase the value of his shares as supply falls.

There is good reason to believe Apple would use a big portion of the money to give back to shareholders as opposed to putting the funds toward its own development and growth.

"Companies' capex and R&D plans take years to develop, and that doesn't change overnight because someone allows you to bring cash back," said Chang. "You can't just switch on and off hiring decisions, factory expansion decisions, based on tax reform."

In an interview with CNBC's Scott Wapner on Wednesday, Icahn stopped short of saying explicitly that he thinks repatriating cash lead to more dividends and buybacks for shareholders, but the issue was clearly on his mind, as was Apple.

"Let's say the whole $2 trillion was done in a buyback or done in a dividend, that would still be great for our economy, because that money would be here in somebody's hands, that money doesn't go in a mattress, people don't burn it. They're in this country spending that money, and they own it, and they're not borrowing it," he said. "So there's nothing wrong with Apple, who has an extra $200 billion, one of the great companies of the world, buying back some of their stock."

But Icahn and other Apple stockholders wouldn't just benefit from shareholder return programs triggered by cash repatriation, they would also likely see a boost in Apple's stock price as Wall Street begins to factor in the cash that, while kept overseas, it has been ignoring.

"Part of why [Icahn] is so over-the-top bullish is because of the cash component, which the street takes a huge discount to given that the cash is basically in jail right now overseas," Ives said. "The street would really have to start to give more credit to the $200 billion in cash that Apple has."

Ives estimates tax repatriation would likely lead to stock appreciation of 8%-to-10%. It would certainly get Apple's stock closer to the $240 target Icahn put on it back in May.

Icahn has been testing the waters in the political realm as of late. He was first thrust into the spotlight when in June Republican presidential frontrunner Donald Trump suggested he would tap his fellow billionaire as treasury secretary. Icahn first declined the offer but has since accepted and thrown his weight behind Trump in September, extending him an endorsement.

"Guys like me ... should be doing much more to get involved in the political arena," he told Wapner.

Representatives for Icahn and Apple did not return request for comment.

This article is commentary by an independent contributor. At the time of publication, the author held no positions in the stocks mentioned.

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