Also, as a meta point, since I seem to see these kinds of challenges often: any time a person is put on the spot to name a specific change to a specific provision of law to enact a policy goal, it's probably going to be difficult to immediately give a specific answer. To translate policy into legislation often requires the assistance of multiple layers of paid staff and legislative analysts.
So the difficulty of answering that type of question is a function of the complexity of legislating, and not necessarily a sign that someone's preferred policy is a bad idea.
Won't help against foreign state sanctioned competitors to Apple, e.g. Samsung (Korea) or Huawei (China).
I am sure foreign nations would be quite happy to gain any advantage for their own companies over US corporations like Apple. Personally I would prefer that the US maintain a technological advantage for as long as possible.
Apple has been using tax strategies since the '80s and pioneered many of the techniques [1]. Samsung or Huawei weren't competitors then (perhaps Sony is the bogeyman you're looking for?)
It also won't make Apple's bezels smaller or write their ad copy for them, because that's simply not among the objectives of any prospective law targeted at reigning in tax havens.
If we need to prop up the U.S. tech sector with special tax handouts because they can't compete, we can do that on a targeted basis when that day comes rather than continuing to perpetuate an open-ended tax giveaway enjoyed by major companies in every sector of the economy.
And in the meantime perhaps we can use the missing revenue to bring our infrastructure up to parity with the rest of the modern world.
That's insufficient. Most of the world has a lower corporate tax rate than the United States. The Cayman Islands might be the most attractive place to park their funds, but pretty much anywhere would still be more attractive than bringing it to the US.
Lowering the US corporate tax rate to say 10 or 15% is the only reasonably feasible solution. Incentivize companies to book profits in the US. Then increase the dividend tax rate to compensate (depending on if this ends up being tax neutral or not -- it might very well be tax neutral given the extra profits that would be booked in the US)
That's more or less what I would suggest. Though, I would probably put the rate at 25% and only tax domestic profits. That would bring US policy in line with the rest of the G7. Raising taxes on dividends and capital gains to make it revenue neutral is also a good idea.
At the moment, tax policy basically penalizes companies bringing money earned in other countries home into the United States. It's stupid. Tax holidays are also stupid. Fix the problem at its heart.
The US reserves these kinds of hostile sanctions for its established enemies such as North Korea and Iran. In general, trade between nations should be encouraged, not blocked by economic nationalism.
