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The 2017 tax reform made it easier for U.S. firms to bring profits booked offshore home (no complex gymnastics required), but it did not - in my judgement - change the basic incentive to shift profits and in some cases jobs offshore. 
The scale of the profit shifting that continues to take place speaks for itself.
What's the solution: Global tax with no deferral would (with credit for taxes actually paid abroad), as would apportioning the corporate tax base on the basic of sales (a Zucman proposal).
What's the solution: Global tax with no deferral would (with credit for taxes actually paid abroad), as would apportioning the corporate tax base on the basic of sales (a Zucman proposal).
There are a number of options that would be substantially better than what we have now. Tis still too easy to move IP and the associated profits to a subsidiary in tax haven, and the low GILTI rate (& the way it is calculated) encourages tax gymnastics.
nytimes.com/2019/02/06/opi…
nytimes.com/2019/02/06/opi…
