I have a client who has elected to have their CFC treated as a disregarded entity.

I'm getting conflicting or unclear information from other sources and the code is confusing me with all the cross references.  As this is a 1 off and their return is pretty straight forward without this I need some guidance on a few things please. 

They made a late election and the IRS accepted this as effective on Jan 30 2019. 

No subpart F income, all subject to GILTI (thinking to elect s.962). Personal service company, no ECI or PTI, fixed assets for QBAI is a computer. No s.965 tax as all losses until 2019. 

1) I noticed their 2018 return has a GILTI loss inclusion reported on their 1040 as the CFC made losses up until 2019. This isn't correct is it?? I'm pretty sure it's not deductible against ordinary income and an amendment is needed.

2) The deemed liquidation of the CFC in Jan 2019. Section 331 right? Is it the acc. E&P taking the PY losses into consideration (CFC made losses until 2019) or the current year E&P (which is large due to a reversal of a PY expense on the books - any way to reduce this - show a book tax timing difference somehow?)? 

3)How does the Section 962 interact with the above? I think it will be a good choice because of the disregarded entity election but will this throw up any funny stuff I'm not thinking of?

4) I'm right to treat this as a short year to end of Jan and report the remainder as a pass through on Schedule C and 8858? I can split it, I don't need to double report the whole year right?

5) The deemed dividend from s.331 liquidation is reported on Schedule B?

It's such a tricky area of tax and I've spent ages researching this but need a bit of practical confirmation before I'm satisfied. 

Appreciate it all. TIA.