It's a good start.
I question section one though- wouldn't it put Atlasian companies at a comparative disadvantage internationally? Say, an Atlasian company is operating in Ireland. An Irish company would be taxed once: by Irish taxes. The Atlasian company, however, would get taxed twice: the standard taxation from the Irish government, and this taxation from the Atlasian government on their investments in Ireland.
Section two is good, in principle; it only needs to be fleshed out a little more. Maybe adapt Franzl's idea.
It would also be a good idea to directly and specifically repeal whatever "tax cuts" currently exist for Atlasian companies to go overseas- NCYankee, you referenced it, do you know the details?
There are no "tax cuts for companies to go overseas". Any tax cut that has ever been given to a corporation could potentially be labeled as such. The tax cuts most at fault I would imagine would passed as economic stimuli in previous recessions to encouraged corporations to expand and hire. However the way the were written left loop holes by which companies were able to engage in mass outsourcing yet still get the tax credit, or cut or deduction. In my opinion the tax cut/deduction/credit is the the catalyst for the outsourcing and if it is, it's very low in terms of whats to blame such as higher US wages, taxes in other categories, regulations etc. The "Tax cut to send jobs overseas", as left wing demogouges call them, are little more then unintended rewards for bad behavior. Hence why I get pissed when leftists and protectionists 1) call it that, and 2) act like repealing it will suddenly create a tidal wave of jobs rushing back in.
The best approach would be to approach the problem as a part of broad based tax reform. By which you would remove most of the deductions, credits, cuts etc for specific companies or industries and then use the savings to slash the overal corporate tax rate.
The next best approach would be to take a fine tooth comb to the tax language in question, get rid of what is uneeded and then tighten the language on what you want to keep.
The end result is you will save a few billion tax dollars which I am all for and the principle of the thing (not rewarding bad behavior) would be upheld. But little else would be achieved beyond that. Except of course, scare the wits out of private capital which inevitably happens everytime politicians get out their crayons and start playing with the tax code.