1. Short title This Act may be cited as the Corporate EXpatriates and Inverters Tax Fairness Act or as the Corporate EXIT Fairness Act . 2. Rules to discourage corporate inversions and impose tax on unrepatriated earnings and unrecognized gains in connection with corporate expatriations (a) Rules relating to corporate inversions and corporate expatriations completed after January 4, 2017 Subchapter C of chapter 80 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 7874A. Rules relating to corporate inversions and corporate expatriations (a) Unrepatriated earnings and unrecognized gains in connection with corporate expatriation (1) In general In the case of a corporate expatriation— (A) the subpart F income of any applicable controlled foreign corporation for its last taxable year ending before the acquisition date shall be increased by the accumulated deferred foreign income of such corporation, and (B) any gain position stock of any applicable controlled foreign corporation which is held by an expatriated entity on the acquisition date shall be treated as sold on such date for its fair market value. (2) Rules related to recognition of gain (A) Application to dispositions during 5 years before acquisition date In the case of any disposition of gain position stock of any applicable controlled foreign corporation by an expatriated entity at any time during the 5-year period ending on the acquisition date with respect to a corporate expatriation, such disposition shall be treated as a sale of such stock for its fair market value and the period of limitation on assessment and collection of any tax with respect to such disposition under section 6501 or 6502 shall commence not earlier than the acquisition date. (B) Gain position stock For purposes of this subsection, the term gain position stock means any stock if gain would arise from the sale of such stock. (C) Gain taken into account