The 2017 Act will require a mandatory deemed repatriation of post-1986 undistributed foreign earnings and profits. The rate applied varies depending on whether the earnings and profits is held in liquid (as defined in the 2017 Act) or non-liquid assets. A proportional deduction on the deemed repatriation will result in a repatriation toll charge of 15.5% for cash and liquid assets and 8% for non-liquid assets.