Repatriation Tax and GILTI Regime

The Repatriation Tax and GILTI (Global Intangible Low-Tax Income) regime are a part of the Tax Cuts and Jobs Act's transition to a system of Territorial Taxation for Corporations. The new tax only impacts businesses and individuals who own corporatized businesses.
The law is meant to provide a "tax holiday" for large corporations who have offshore subsidiaries with profits as yet un-repatriated (undeclared in the U.S.) The tax deems the profits to be "repatriated" - and, therefore, taxable - but taxes them at a discounted rate. Clearly, the businesses owned by Americans living abroad are meant to sustain them in the countries where they live; not push profits back to the US. They were inadvertently clawed into this new tax regime which was never meant to apply to them. Additionally, corporations with foreign subsidiaries are entitled to deductions and offsets whilst Americans living abroad with foreign businesses are not.
Democrats Abroad went to Capitol Hill to discuss this harmful new tax, in addition to Residency Based Taxation, FATCA, WEP and more. We outlined the serious financial hardship the provision will cause businesses abroad and asked for support for an exemption for Americans who live and own businesses abroad.
We understand that Congress has generated a lengthy list of problems arising from the hastily drafted Tax act and we learned that very few of them will be "fixed" in the short term, though the March Omnibus appropriations bill provided a good opportunity.
As the Repatriation Tax declaration is to be included in 2017 filings, time is of the essence in addressing this problem. We would like the IRS to issue guidance confirming that non-resident taxpayers who own businesses will not be required to advance payments on the Repatriation Tax until adequate guidance is issued. We are also seeking an exemption from both Repatriation Tax and GILTI.
Those with questions about how they might be impacted by the new law should consult professional tax return preparers.