I think the purpose of VC is to distort markets. What the tax code is trying to do here is to incentivize VCs and entrepreneurs to take risks. At the same time

I think the purpose of VC is to distort markets. What the tax code is trying to do here is to incentivize VCs and entrepreneurs to take risks. At the same time, you need anti-abuse to keep people from unfairly taking advantage of the incentives. This ends up being complicated. Maybe something like a 10% corporate AMT would help. Your WSGR startup lawyer will strongly recommend against trying A Double Irish Dutch Sandwich. Apple can do this because they will hire an army of lawyers to keep the Feds busy. You can't but at the same time you have to compete with Apple and Google and .... A corporate AMT would help level that playing field. Won't happen.