What will be the distributional consequences of this tax overhaul?

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According to Neil Irwin, our current tax system is infinitely complicated and it gives companies incentives to borrow too much money and move operations to countries with lower tax rates. With the House, Senate and presidency all soon to be in Republican hands and with all agreeing that a major tax bill is a top priority, some kind of change appears likely to happen.

Questions:
1. What type of change does Irwin suggest will happen?
2. What does D.B.C.F.T. stand for?
3. What were the two prime examples that Irwin gave regarding overseas transfers?
4. What are the risks of this model?

Source:
Irwin, N. (2017).The Major Potential Impact of a Corporate Tax Overhaul. The New York Times,Jan. 7 (Retrievable online at http://www.nytimes.com/2017/01/07/upshot/the-major-potential-impact-of-a-corporate-tax-overhaul.html)