with a (shimano type) splined tool it can be bolted to the cup and then a suitable spanner/socket can be used. I have used a 36mm socket on a 3/4" drive breaker bar with an extension on it, making a total length of about 5'. The problem then becomes holding the frame; to get enough leverage here, lengths of tubing are used (with care) in the head and seat frame tubes. To my surprise the splined tool (a shimano one, of a kind I have seen break in other people's hands) has survived this treatment several times now. Thinking about it the peak torque used to date would have been far in excess of 400ftlbs. Part of the trick of it is to use a flex-headed breaker bar; this allows the handle to be brought back into the same plane as the frame, so that there isn't a secondary couple that you need to fight against, and your effort is not wasted.
If a length of bar is welded to a steel cup, this can be extended using a cheater bar of some kind, or just slogged. The heat from welding usually breaks the bonds of corrosion to some extent; slogging is highly effective but gives rise to uncontrolled forces. Usually the welds to the cup break before the frame does but there is no guarantee of that.
Seized aluminium cups often require a destructive approach. Once the bearings are removed (by hook or by crook) an aluminium cup can be slotted (sawn) and broken up. If this is done with care, there will be minimal damage to the BB threads.
BTW I forgot to mention; one trick that is widely used in bike shops to remove seized BBs is to 'massage' the BB shell using a hammer. The best method is to use two hammers; one with a large, heavy head is set against the shell on one side as a bolster. The BB shell is the struck using the other, smaller/lighter hammer on the other side, i.e. 180 degrees round from the first position. If this is done in several places a seized BB cup usually comes free. It damages the paint of course, and even the frame sometimes, but it can result in a time-efficient (and therefore economic) repair that might otherwise not be possible.
cheers