“Since the corporate income tax began in 1909, Congress has imposed a penalty tax, currently 15 percent, on excess cash and near-cash... Without such, a corporation could... become a huge tax shelter, withdrawing resources from the economy instead of investing in new plant...equipment... jobs and paying dividends... But President Reagan signed a law that... so long as the money was owned by offshore subsidiaries, American companies could hold unlimited amounts of cash. ...[C]ompanies now siphon profits out of the United States under the guise of... tax deductible expenses...”