The so-called Dutch Sandwich exists because the United States is the only country in the world to practice worldwide-basis taxation. In any other country, that

The so-called Dutch Sandwich exists because the United States is the only country in the world to practice worldwide-basis taxation. In any other country, that income would not be taxable at all. Which is not to say that there are no issues with correctly attributing corporate income to the countries in which it occurs, but figuring out which governments are entitled to which corporate income is a fantastically complicated question without clear answers. It's certainly not obviously the case that the United States government deserves a share.