If I understood correctly, the problem is that the money made abroad, is made by using the intellectual property owned (and presumably gained) in the U.S and so

If I understood correctly, the problem is that the money made abroad, is made by using the intellectual property owned (and presumably gained) in the U.S and some people think the U.S. should get a share of those profits. However: 1) while it's true that good part of the actual work has been done in the U.S., great part of the value comes from the effort (marketing, sales, R&D, ...) that happens in the subsidiaries; it's not easy to quantify, but certainly those people are actually doing something, aren't they? 2) as far as I understood, the U.S. income tax is not paid until that money gets back to the U.S. In fact it stays abroad, deferring the tax payment. The subsidiary could use that money to invest and expand the foreign market, with indirect but substantial domestic benefits. I believe the issue of tax loophole in the country where the actual subsidiary works, is a different matter; but I don't understand what's the problem per-se with having stashes of oversea money held by a foreign subsidiary of your company.