The bolded words are the key. You can shift profits to foreign subsidiaries, but you can’t actually return them to US shareholders without bringing them back into the US and paying tax on them (unless you can convince Congress to give you a pass).
The difference (as I roughly understand it) in the UK is that UK law doesn’t tax foreign profits at all, even if they’re brought back to the UK and distributed to UK shareholders. Hopefully some Brit will correct me if I have that wrong.
