I've known individuals pay the difference between foreign tax and US federal tax, but I'm not so sure that also applies to corporations. I'll need to research t

I've known individuals pay the difference between foreign tax and US federal tax, but I'm not so sure that also applies to corporations. I'll need to research that. You really can't start dictating the terms of contract agreements between domestic and foreign entities with regard to "royalties" or other such payments. It would adversely affect any other companies as well that are not subsidiaries. And before you attempt to limit the rules to "subsidiaries" consider that although "Apple Ireland" is somehow affiliated with "Apple, Inc" in the US, they are wholly separate companies with a contract to behave in certain ways. Should Apple Ireland, being a separate company, decide to 'go rogue' breaking the contract and doing whatever they will with all 'their' money, they just get cut off from the Apple, Inc ecosystem and a new entity is created that will play the game correctly. So how do you force "Apple, Inc" which is a separate company from all the other "Apple $PLACE" around the world to pay tax on money that, legally, it doesn't have ... without also adversely affecting any number of smaller companies that couldn't possibly bear such a tax burden?