You don't understand how companies manage their tax obligations. It's not like that. For example, look at how Apple manages it's international tax burden.

For example, it's international profits are generated by international subsidiaries, which are different companies that Apple owns the stock of. Their profits are taxed in the country they are based in. They have two choices:

1) What's left can be paid to the parent company, Apple USA, which would require paying about 42% of those remaining profits to the U.S. and California governments.

2) What's left can be invested in an Irish subsidiary, and the bank interest those funds earn will be taxed at a special low rate by Ireland because they'd rather have that money invested in their economy then invested elsewhere. Eventually when the U.S. decides to lower the rate on repatriated profits, Apple will move the Irish deposits back to the U.S., pay about 20% of them in federal and state taxes, and most of the rest out as dividends to Apple Shareholders, who will pay something like 20%+ state income tax rate on the remainder.

So no loopholes, just following the letter of the law and making decisions to not do things that would trigger massive tax penalties.

And if you wonder if Apple should be forced to pay U.S. income taxes it's entire world wide income, like some crazy people have proposed, think of the consequences. Apple's effective corporate tax rate would be roughly 50% a year, and the effective tax on dividend distributions would be around 70%, even if you were a little old lady living on social security that had your meager life savings in Apple stock.

Meanwhile Samsung's rate would whatever South Korea chose to allow it, likely far far less. And it's international profits might be taxed even lower. So Samsung would have more after tax profits to reinvest in it's businesses and over time that would be a huge advantage over Apple, just like every international company would have over U.S. companies.

At that point, why would Apple remain in the U.S? Why not move the HQ to Ireland, and make Apple USA a subsidiary of it? Why would any super profitable US company not move, to literally any other country?

Lastly, the real point is that corporations should never pay income tax. Their profits are either reinvested in the business, which means creating more jobs, increasing productivity (which raises wages) and making more and better stuff. Or they are invested in other investments, bank deposits etc, which are loaned out to do pretty much the exact same thing. Or they are paid out to shareholders, who then have to pay taxes again on the dividends in a flat, non-progressive system.

We want investment into companies. We need investment into companies. Without it, no company can grow or develop.

If 50-70% of the profits from your investment are lost to taxes, you are going to be far less likely to invest in a U.S. company. If 100% of the profits are paid to you so you can pay your own personal tax rate on them, you are going to be much more likely to invest in a U.S. company. So I say dump the corporate income tax, dump the special dividend rate, and let investors pay taxes on dividends at fair rates in our progressive rate tax system.