you can keep the money off shore and pay the taxes later though, no?
Speaking generally, if a corporation is owned by fewer than 10 US taxpayers, there is no effective deferral. This is based on the assumption that closely-held companies are being operated at the behest of the owners and will be structured in a way that is tax efficient for the individual owners.
Public companies are not subject to these rules, and they can defer paying tax on some types of income.