The problem is more fundamental: corporate profits are easy to move, and make a poor practical target for taxation. Corporations are free to optimize their stru

The problem is more fundamental: corporate profits are easy to move, and make a poor practical target for taxation. Corporations are free to optimize their structure for tax purposes, so there's nothing stopping the surplus cashflow from returning as bond coupons, intellectual property rent payments, or whatever other clever thing that doesn't book "profits" in the taxing jurisdiction. Like, as a concrete example, suppose you're an American who owns some car washes in France. $15m in sales, $10m in costs, $5m profit. You could do an equity-for-debt swap, and own the exact same assets in the form of bonds that pay $3m per year and a more indebted company with a $2m per year profit. Poof, you've just moved $3m of European profits and transformed it into $3m of American interest income. Maybe not the best idea, but if you live in the right jurisdiction...