1. Short title This Act may be cited as the Corporate Tax Dodging Prevention Act . 2. Deferral of Active Income of Controlled Foreign Corporations (a) In general Section 952 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (e) Special Application of Subpart (1) In general For taxable years beginning after December 31, 2017, notwithstanding any other provision of this subpart, the term subpart F income means, in the case of any controlled foreign corporation, the income of such corporation derived from any foreign country. (2) Applicable rules Rules similar to the rules under the last sentence of subsection (a) and subsection (d) shall apply to this subsection. . (b) Treatment of previously deferred foreign income (1) In general Section 965 of the Internal Revenue Code of 1986 is amended to read as follows: 965. Inclusion of previously deferred foreign income (a) Inclusion as subpart F income The subpart F income (determined under section 952 without regard to this section) of a controlled foreign corporation for its last taxable year beginning before January 1, 2018, shall be increased by the accumulated deferred foreign income of the corporation. (b) Accumulated deferred foreign income For purposes of this section— (1) In general The term accumulated deferred foreign income means the excess of— (A) the undistributed earnings of the controlled foreign corporation, over (B) the undistributed U.S. earnings of such controlled foreign corporation. (2) Undistributed earnings (A) In general The term undistributed earnings means the earnings and profits of the controlled foreign corporation described in section 959(c)(3), determined— (i) as of the close of the taxable year described in subsection (a)(1), (ii) without diminution by reason of distributions made during such taxable year, and (iii) without regard to this section. (B) Special rule for current year distributions For purposes of this chapter, any determination with respect to the treatment of distributions