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> there are a bunch of dumb tax rules that already allow taxes to be avoided as long as the money isn't repatriated

I think that was just in the US; but the Trump tax changes got rid of global taxes on US companies, payable on repatriation and replaced it with essentially a minimum tax on global income, payable immediately, but credited by foreign taxes paid; plus a different rate on US income.

IIRC, the global minimum rate is about 10%, and the US rate is about 20%, and there's probably some progressivity, so those are the top marginal rates, but this isn't tax advice.