Regarding 4, specifically "to realize losses in the US and gains in a foreign country", how do you propose companies avoid this situation? Should they deliberately lose money overseas as well? What would this accomplish?
to answer 4. The point of this is to stop companies from making subsidiaries in another country to realize gains, and then wait for a tax holiday for repatriation.
Why not just not give out tax holidays, and allow foreign companies owned by US companies to leave profits overseas forever? Granted, this will reduce investment in the US, but we don't care about unintended consequences.