I would like to gain the community's perspective on what they are finding with the Repatriation Tax/GILTI. I will start with some of my own findings.
1. There was a rush to put US taxpayers individuals with CFCs in S-Corps by 12/31/17 in order to defer the repatriation tax. While this might be a good idea for repatriation tax purposes because the repatriation tax would only be triggered by certain events, this is a bad idea for GILTI because the S-Corp is not eligible to receive the 50% reduction in GILTI income or FTCs, which seems to have made the whole exercise pointless.
2. The Sec. 962 election which enables US Taxpayer to be treated as a corp for SubF purposes, does not provide any benefits for GILTI tax. So, there should be a rush to set up a US C corp and transfer foreign shares into it, rather than relying on the 962 election, which is due on next year's return.
3. CFCs in non-treaty countries could realize a very high ETR because they dont get qualified dividends.
4. There are different views on whether you use corporate rates of 15% and 8% or a higher derived individual rate for a US taxpayer. The code only refers to corporate rates, but that makes no sense because you are applying corporate rates to individuals.