Yes, but it was meant to prevent double taxation, so unfortunately it's not as simple as just revoking it.

My view is just that increases in equity of firms held overseas, where the US firm holds a controlling share (i.e. greater than 50% of voting shares) should be subject to taxes as corporate income taxes. It also neatly avoids the problem of double taxation on the basis of dividend payments. Dividend payments would be deducted for overseas holdings before taxes, meaning that the dividend payment gets taxed as income but so does the post-dividend retained earnings. For overseas holdings of less than a controlling share it seems to me that whatever rules exist for capital gains would apply. If that's not enough offer a tax credit equal to foreign taxes paid.

I also think our approach to capital gains needs to be rethought. I understand why taxing capital gains as straight income is undesirable especially where the middle class is involved and where gains off home sales may be a factor. However, I wonder if a better option would be to allow capital gains to be folded into income going forward, amortized for the period of time the asset was held. So if you live in your home for 10 years and sell it at a capital gain of $500000, then you would add $50k to your reported income for the next 10 years following the sale. This would also privilege retirement accounts because at some point the amortization period would exceed life expectancy.

This would neatly address the issue of the super-wealthy paying a lower tax rate than the middle class, while continuing to favor retirement-oriented and long-held assets.