1. Companies which parent owner is based in the US. Companies are already paying taxes based on consolidated regime, it is just that they consolidate all entities within a tax jurisdiction. So the concept exists, it could just be extended.

2. You wouldn't have a double taxation. You would apply to companies what the US applies to US individuals. If you have a subsidiary in Germany and paying local taxes of 10, but that would be paying 15 if you had the same income in the US, then you owe 5 to the US taxman in addition to the 10 you owe to the German taxman.

Alright here are my new loopholes to evade your amendments: I'll set it up so that my other company in the other country is sharing profits with my main company. Maybe I'll have a family member or someone I trust actually own that company. Perhaps this doesn't work for some reason that already exists in the tax code, but I've already met the letter of the law that you spelled out here. Obviously that would be easy to fix with some further amendments but the problem is that this back and forth we are having is happening at a larger scale through the years. And in real life I have 10-1000 times as much money to figure out how to defeat or get around your tax codes.

I think what you are describing is a company not based in the US not having to pay this tax. Effectively companies fleeing the US. Agree that this would likely be a consequence. But that's the price to pay to maintaining high tax rates. Countries don't like competition but the reality is that this competition exists among them.

I don't think Apple and Google can flee to Bermuda or Ireland and that's not what I was talking about. The employees aren't going to move.

I was just pointing out a simple loophole in the specific rules the you proposed as a rhetorical tool: it's very, very hard to write a loophole free tax code in light of the inherent complexity of having many nation states and multinational corporations. At the very least, it should become a cultural norm for companies like Facebook, Apple and Google to report tax loopholes even as they exploit them.

You still have double taxation because of dividend taxes. The US has one of the highest corporate tax rates already, as a country we’d be far better off making it zero.

> You still have double taxation because of dividend taxes.

Corporations are distinct from their owners, that's the whole point of a corporation. That's not double taxation, it's single taxation of two separate entities, one of which acts as a liability shield for the other.

> The US has one of the highest corporate tax rates already,

Nominally, but one of the lowest effective corporate tax rates

Whether it’s two seperate entities or not, the disincentive is still the same. Investors who want to start a business in the US have to pay > 50% of their profits to taxes before they receive them.

And the high US Corp tax rate isn’t nominal, it’s real. Apple appears to pay a lower rate, but that’s only because of most of it’s profits are earned overseas.

If it paid 10% on two thirds of its earnings earned overseas, and 40% (state and federal income tax) on the one third earned in the US, it looks like only an 19% total income tax rate.

But when it returns the foreign earnings it pays another 40% state/federal on them, for a blended rate of 43%. And shareholders owe dividend and state taxes on top of that.

Tax deferral isn’t avoidance. Even if Apple gets a 10% repatriation holiday, their blended rate is still over 30% and total for shareholders over 40%.

Money is taxed every time it changes hands or moves around. When I get my paycheck, I pay taxes on it. Then, when I buy a ham sandwich, the shop owner pays taxes on it. Is that unfair "double taxation?"

We aren't talking about taxes on "money", we are talking about taxes on investment.

Investments are made to return profits, the more of the profits society takes, the less incentive investors will have to start and grow companies. So you should think about what tax rate you think we should have on investment.

Right now if you and friends start a business in the US, for every dollar in profit you'll first owe state income taxes, and federal corporate income taxes, which is anything from 35-45% depending upon your state. That's even if you re-invest every penny of profit into the business, into new jobs and higher productivity improvements. Why as a society are we reducing earned capital by more than a third every time it's reinvested?

Then, if you ever want to pay a share of those profits to your investors as dividends, now there is another 15-35% tax, based on state/income tax brackets. That's the double layer that means US companies lose at least 50% of profits and up to 70% to taxes before their owners get any.

Do you really think business owners should pay 50-70% of their profits in taxes? Then don't mind if some decide starting their business in a lower tax country makes sense.