Stubs for Foreign

Tax gain upon expatriation.
Define domestic corporations to include those with place of management, etc. in the US, in conformance with the rules of many other OECD countries.
Provide that tax liens secured against U.S. persons for income from foreign tax havens may be applied to property owned directly or indirectly by entities with which that U.S. person has, directly or indirectly, entrusted or invested funds. For example, if Fred Jones has a tax lien for non-payment of income taxes on income earned from a Cayman Island's bank, any assets of that bank, even if held through nominee accounts, etc. would be subject to a U.S. tax lien as a result of Fred Jones' non-payment of taxes.
Tax the global income of all companies that do business in the United States on a consolidated basis with income allocated based upon sales, employment or other real world drivers, rather than relying upon transfer pricing regimes.