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That would be quite the tax. Developers in Europe and Asia make a LOT less than the US.

that's kind of the point, you want to eliminate companies just doing labor cost arbitrage rather than hiring globally because they actually need a unique talent they can't find in the US. If that's the case, they will happily pay the premium because that person still provides ROI even at US pay rates. That's supposed to be how H1B visas work as well

What's to stop Apple, for example, from setting up companies all over the world that employ their people and own their IP local to the employees? Then Apple US buys / licenses products for US distribution from those companies.

Massive companies have far more incentive to "engineer" their way around such laws than lawmakers have to find something without loopholes. Especially given how lobbying works in the US.

To "own" those companies Apple has to participate in trade agreements between both countries respective legal systems, and also know those agreements mean something.

If your foreign subsidiary is owned by citizens of the country it's in, then how exactly do "you" own it if your claim to ownership doesn't in fact depend on agreements between the respective governments?

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