The money wouldn't just be taxed eventually, it would also be taxed immediately, though at a reduced 5.25% rate instead of the usual corporate tax rate. And if

The money wouldn't just be taxed eventually, it would also be taxed immediately, though at a reduced 5.25% rate instead of the usual corporate tax rate. And if a corporation repatriating income uses it to pay dividends, or for share buybacks (resulting in capital gains), this will result in taxable income for the shareholders.