In some cases, amending can result in a sizable refund. If your Repatriation Tax was calculated conservatively (due to the absence of clear guidance at the time), then you may have overpaid the original tax. By amending your returns timely, you can recover the refund. In other cases, if you under-reported (or failed to report) the Repatriation Tax, you may be at high risk.
While it’s true that the Repatriation Tax guidance from the IRS has been confusing, the IRS is now pursuing taxpayers who did not properly calculate and pay the tax with their 2017 returns. The IRS originally expected to raise between $339 billion and $4 trillion from the Repatriation Tax. Instead, taxpayers only reported a very small fraction of that on their tax returns.
As a result, the IRS sees this as an area worth investigating. It held an amnesty program in 2018 to give taxpayers a chance to correct their Repatriation Tax filings. If you missed the amnesty program, other options are still available to correct your Repatriation Tax reporting. But, to correct your filings under favorable terms, you must fix them before the IRS audits your return for Repatriation Tax violations.