The foreign profits tax "loophole"

Since it is April 15...Much political hay has been made about the supposed "loophole" that allows companies to defer US taxation on profits earned overseas until those profits are repatriated. Is this really a loophole, or is it simply consistent with how most profits on investments are treated? Consider the following.

Scenario 1: You're an individual investor and who buys a share of stock in Toyota in January for $100. Over the course of the year, the company earns $5/share in pre-tax profit. They pay corporate taxes of 20% on their earnings, so your share of the after-tax profit is $4. The local government collects $1/share in tax revenue. The company pays no dividend and reinvests those $4 profits into developing new products, hiring workers, expanding factories, etc. At the end of the year, your share is now worth $104. You haven't sold your share, so your profits are unrealized, and the tax you owe is $0, because although your investment is worth more on paper, you haven't actually received any cash. You have deferred your tax burden until you either sell the shares or receive a dividend.

Scenario 2: You're a corporation who buys a small company that owns several companies in Estonia for $100 million. Over the course of the year, the subsidiary earns $5 million in pre-tax profit. They pay corporate taxes of 20% on their earnings, so your share of the after-tax profit is $4 million. The local government collects $1 million in tax revenue. The company pays no dividend back to the US and reinvests the $4 million profit into developing new products, hiring workers, expanding factories, etc. At the end of the year, your investment is now worth $104 million. Your company in the US hasn't received any cash or profits and under the current system you wouldn't owe any additional tax on top of what the subsidiary already paid the local government.

However, if the tax laws were changed to make foreign income taxable, you would have to immediately pay US taxes on the entire $5 million, even though the parent corporation never received any cash from the foreign subsidiary - all the cash and profits were either paid in the first round of local taxation or reinvested in growing the company.

This is a highly simplified example. Obviously there is a distinction between normal foreign earned profits and truly abusive tax shelters in some countries that should be eliminated. But this example shows that foreign earned profits are not much different than profits earned on other similar investments. So is it equitable to treat them differently? Investors who have a 401k or IRA also take advantage of tax deferral - is that a "loophole"?