Is the problem the current tax code, or the fact that companies know they can pay politicians to change the tax code in their future to favor them, and they just need to wait it out?
If companies knew they were going to pay the tax one way or the other, there would be no point in hoarding overseas.
We should penalize companies for the behavior until it makes more sense for them to repatriate it immediately.
The current offshore “hoarding” is actually due to the current tax code.