So it's permanent spite now? Force your companies to pay taxes in the US forever or permanently bar them from US markets?
OK, so what do you do with an asset sale then? Sony picks up all of the assets of Columbia but leaves the corporate shell to die. Are you taxing Sony as a domestic now? It isn't and never was an American entity.
See, companies don't do that now because of potential adverse tax implications, but you are leaning pretty heavily on the scales on that one.
How about this. Columbia spins off its foreign business through an asset sale to a company with ownership identical to its current shareholders and sets up reciprocal long term supply agreements. So you have Columbia US which is American but the rest of the business has its own floated stock and no US business. Again, makes no sense in the current environemnt, but makes far mroe sense if you are proposing to try to extract billions from them every year.
And again, what do you do with the Canadian car wash business that dips a toe into the Buffalo market? Or the ag company supplying you with fertilizer? Or blackberry or Samsung or H&M or Fair Trade Coffee importers? You have no answers because you prefer not to think these thigns through. You are trying to develop policy based on emotion and your grievances with those who are more successful than you, rather than with legitimate policy goals and a well-thought out understanding of how markets work.
And the "analysis" is exactly what you would expect as a result.