How to Stop Turning U.S. Corporations into Tax Exiles

Is the end to double taxation for the corporate tax only? Human Americans are also double-taxed on income earned abroad.

I agree with you in general but there is another thing you're missing: the double taxation discourages investing in new businesses in the United States.

If a VC is looking at two very similar businesses selling internationally, with one seated in the US where their profits will be doubly taxed, and the other running in a different country where profits are not subject to this, then ceteris paribus, they should expect investment in the non-US company to be more profitable.

Everything over the deduction (currently just shy of $100k) is taxed, minus a further deduction for tax paid to a foreign government on the earnings. Basically, you will pay the higher of US tax or local tax, on earnings over $100k. And you're right, most people don't pay.

Really the bigger pain in the ass is that you even have to file. I've filed tax returns to the IRS for the last 10 years despite not paying a cent of tax to the US during that time, since my local tax is higher anyway. It's ridiculous. And come to think of it, even if they did end the double taxation, it's likely they'd keep making us file, the assholes, considering they also recently began to require that we make a yearly report to FinCEN in addition to the IRS.

I am trying to think of companies that should rightfully repatriate cash back to the states, and companies that should not.

Why is it that it is repulsive that Google or Apple chooses to keep their cash overseas, whereas it is fine for Budweiser to do so (ignoring magnitudes for a second)? Because AB Inbev is Belgian? This is a difficult example for me to think of, because the US is one of the interesting countries where the largest companies here (or globally) are almost always American too.

But let's imagine for a moment that there is a company called Apple Inc that only does business in the US and nowhere else, and there is an unrelated company in France called Pomme SA, and another unrelated company called Apfel AG in Germany that happen to sell identical iPads and iPhones. Do they have a duty to transfer cash to each other and their jurisdictions? What if the CEOs of these companies travelled and met each other and went, "oh! we did not know it but we sell the same thing, let's share resources in some way", which country has a right to collect tax on the revenue of the new global organization?

The real debate is really about fairness in transfer pricing (which is difficult if not utterly boring, because typically transfer pricing are for services that are not fungible or even exchangeable in arms length markets, and so the debate within tax jurisdictions are over the nitty-gritty "economics" of the transaction in addition to consideration of foreign tax obligations yadda yadda yadda yawn), and this tax evasion through scary financial structuring like "inversion" is a really catchy thing to publicly excoriate, but it's probably not the right concern. So this is kind of a stretched example.

The point I am getting at is that many American companies aren't 100% American, and it doesn't seem like there is a good reason for insist that all foreign earned cash (from Apfel and Pomme) to be brought back to the US. I do not agree that a company like (say) Royal Dutch Shell, being one of the largest oil companies here, should repatriate cash into the US, and unanimously most of us don't think so, so this is not really the problem we should be getting angry about.

I agree to an extent, but nations are also competing on all of these other factors that make them more attractive places to do business. Some costly health care surcharge in France could be reduced as easily as the foreign profit taxation in the US.

Also, it only takes one Ireland to drive the entire world toward 0%.