There are several strategies the US government can use to prevent companies from using untaxed foreign profits without repatriation. These include: - Strengthening and enforcing transfer pricing rules under IRC Section 482. This can be done by enhancing documentation requirements for intercompany transactions, increasing audits to ensure compliance with transfer pricing regulations and arms-length pricing requirements, and imposing stricter penalties for non-compliance with transfer pricing rules. - Apply minimum taxes on foreign earnings. Under IRC Section 250, the US government can give incentives for companies to keep their intellectual property and associated profits in the US, thus reducing the need to shift profits offshore. - Give repatriation incentives. This can be done by offering reduced tax rates or tax holidays for repatriated earnings, which can encourage companies to bring foreign profits back to the US, and by providing tax credits for foreign taxes paid to prevent double taxation and encourage repatriation. Aside from these, there are still other strategies that can be employed to encourage repatriation and prevent the use of untaxed profits