[mercutio2]

Where money is domiciled is orthogonal to what currency or bank the money is held in.

Similarly, the ability to borrow against assets which are domiciled in a different country is pretty much how international banking works, not a loophole.

The US created this quagmire by choosing (unlike all other modern countries) to tax profits in all territories. Then they combined this with only taxing the profits when they're repatriated.

This legislative own-goal is the root of the problem, it seems to me.