I think it's theoretically inelegant but may be what is most practical, especially in a race to the bottom global economy. More than one company has reincorporated in high-tax countries like the UK and Switzerland, because of favorable corporate taxes. The executives pay more, but it gooses earnings which is what the analysts want to see. We don't get much revenue from them anyway and it'd be better to keep the companies and the capital here.
We could get rid of most of the corporate tax code that way -- and corporate taxes, as you point out, are always gonna be complex.