IANAL, but https://www.law.cornell.edu/uscode/text/15/80a-20 suggests there are structures that would be permissible.

For example, something like a pooled company that exists to provide this service for dozens of corporations thereby meeting ownership dilution requirements to avoid triggering circular ownership statutes.

Corporate tax lawyers are bright (a well-deserved compliment). Someone would figure out how to hack it. And then the well-intended hypothetical law would just put money into the pockets of lawyers and accountants at the expense of shareholders. It'd sound great on a campaign trail but be stupid in practice.