Did you notice that he intends to tax the money held overseas at 10% whether or not the money is returned to the US? Since when is the U.S. taxing money earned in another country and that remains in that country a conservative policy? No other major country in the world does that, and that policy is one of the key policies driving the corporate inversions we have seen.
All personal income, regardless of where you earn it, is considered US taxable income, if you are a US resident or citizen.
Why not do that to business income?