Does the 'one time repatriation tax' refer to companies or individuals?
The issue you're referring to is still unclear, even after the release of the text.
The intention is for the large corporations only, but, according to some North American tax experts, the wording (and Sections of the Code referenced)
MAY apply to individuals with a 10% share or more in a CFC. If so, some in the UK would have a problem (14%/7% on P&E going back to 1986).
It's really unclear: it may be a storm in a tea cup; the committee knew about it but didn't clarify; it may be corrected (if accurate) in later clean up legislation; how will the IRS react to those who just ignore it; and on and on.
There's no definitive answer at this time.