>With that much money at stake it's guaranteed the best financial/legal minds on the planet will do their best to find workarounds. And not just the companies with overseas holdings, but the tax havens that are benefiting from the current arrangement.

It's more likely that I'll win the upcoming Masters golf tournament (a recurring fantasy) than that this idea will do more than provide Fox News with some anti-Obama ammunition.
Given the congressional makeup, it will never see daylight.