This is pushing the bounds of my tax knowledge, but I don’t think the loophole you describe would work in the US, because US tax law already taxes all the profits a US corporation makes anywhere in the world. The UK system (about which I know only a little) has to specifically target tax havens for repatriation taxes (enabling loopholes like you describe), whereas the US system automatically has a repatriation tax, so the main loophole is if you can convince Congress to suspend it for a while.
