that if non-liquid assets. (final rates not set yet, started at 12% iirc) And so what if it goes to dividends or buy backs? Those are taxed again above the repatriation tax as dividends or higher Cap Gains. And then provide more liquidity to individuals for higher consumption, investment, etc. for growth.

Also, please note 5.25% on $312B is over $16B in revenues (much higher if same amount under these rates obviously), plus additional revenue on the personal side and resulting growth/spending. Not exactly revenue to sneeze at (and this should be much, much higher). Finally, keep in mind those profits were already taxed by a foreign entity (granted at a lower rate, or in some rare cases no rate), so bringing them back is tax on top of that already paid elsewhere.

Repatriation is a no brainer from a revenue stand point (should be even lower rate IMO to get more back). After that, I believe it will be treated like the personal side (or should be), if you recognize and keep/move those profits here, you pay 21% or the difference between what you paid elsewhere and 21% (6% if you paid 15% elsewhere, 0% if paid 21% or higher elsewhere). The goal should be to get rid of incentive to move profits for tax avoidance purposes only.