Many (most) US multinationals pay little or no real tax on their income due to tax shelters. Sometimes these billion dollar companies pay simply zero (0) annually.
Rather than negotiate with these companies their assets should be frozen as any individuals would be.
Its not just a few companies. Its all the companies doing this. Its a national disgrace.
Even your own bank has your money in the Caymans, as does your employer, etc etc.
There can be no fairness when the clever opt out.