What needs to be done is change the unique incentives for American companies to participate in such byzantine international tax avoidance schemes in the first p

What needs to be done is change the unique incentives for American companies to participate in such byzantine international tax avoidance schemes in the first place. The US is practically the only country that taxes profits internationally regardless of origin. It should remove all taxes on bringing foreign profits into the US and lower the overall corporate tax rate while closing the loopholes that render the 'headline rate' so ineffectual in the first place.