Right now, few firms repatriate unless they either have to, or they specifically intend to pay that out to shareholders. There’s no reason at all to repatriate otherwise. So the situation now may have nothing to do with the potential situation under discussion.
Do you have a reason for that amount, or was it just picked out of the ether? 25%is probably much too hig. Why give up a quarter of your cash if you can use much cheaper Caribbean banks? Yes, small Caribbean banks are the competition here, and if you want to win money away from them you have to attract it. I’m sure many companies would love to use home office banks for netting* and fund redistribution, but it’s just too expensive, and changing it to 25% is unlikely to change that.
*Netting is the basic procedure used to balance global accouts in international corporations. It quite often uses offshore banking.
If you’re going to pick an amount it should either be a very small flat percentage, or simply require the company to treat the money as income, which will be larger but variable depending on revenue.
Also, while I can’t speak for the OP, I really don’t want to hear any whining about how corporations are “cheating the system” or “not paying their full share” by not repatriating. Amazingly enough, if you tax the shit out of something, people do less of it. Try to change that, and you’ll simply force companies to relocate outside the U.S., hide their accounts, or find new ways to avoid it. In fact, now that I think about it, that’s kinda what happened in Greece.
However, consider what you’d gain by doing so. First, home banks would have a lot more capital, making it cheaper to lend. Banks would be more stable, while offering cheaper capital to U.S.-based businesses and individuals. There’d be more basic banking jobs, while at the same time makin it easier to . And if you nab enough market share and make the U.S. attractive as a financial holding center, you could even see tax revenue from repatriation increase.