If the foreign tax rate was 20% and the US rate was 35%, they’d still owe the 15% difference to bring the profits home.
We are one of the few countries that taxes our corporations on their world-wide earnings. A Japanese firm that earns a profit anywhere in the world can bring that profit home with no additional tax.
In that sense, our corporations are double taxed. And we had one of the highest corporate rates in the world.
The money was made outside of the US taxation authority. It was taxed as if it was made here. Its double taxation. If you work in state A and deposit your pay check in a bank operated in NY should you pay NY state income tax at all ? No. If you did would you call that double taxation (taxed in 2 states). Why should the federal government get its hands on it. Also the old 35% rate was one of the highest in the world.
2 nations taxing the same money for the same reason sure seems like double taxation. Perhaps if it happened to you, the term might not be as annoying as the fact.