1. Short title This Act may be cited as the Pay What You Owe Before You Go Act . 2. Recapture of unrepatriated earnings of groups including an inverted corporation (a) In general Section 7874 of the Internal Revenue Code of 1986 is amended by redesignating subsection (g) as subsection (h) and by inserting after subsection (f) the following new subsection: (g) Recapture of tax on unrepatriated earnings (1) In general 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 the corporation. (2) Applicable controlled foreign corporation For purposes of this subsection— (A) In general The term applicable controlled foreign corporation means any controlled foreign corporation with respect to which— (i) a covered entity was a United States shareholder at any time during the 5-year period ending on the acquisition date, or (ii) a member of the same expanded affiliated group as a covered entity was a United States shareholder at any time during the 5-year period ending on the acquisition date. (B) Covered entity The term covered entity means, with respect to a controlled foreign corporation, any entity which— (i) is treated as a surrogate foreign corporation under subsection (a)(2)(B), determined— (I) by substituting July 24, 2017 for March 4, 2003 each place it appears, (II) by substituting more than 50 percent for at least 60 percent in clause (ii) thereof, and (III) by disregarding clause (iii) thereof, and (ii) is not treated as a domestic corporation by reason of subsection (b). (3) Accumulated deferred foreign income For purposes of this section— (A) In general The term accumulated deferred foreign income means the excess of— (i) the undistributed earnings of the controlled foreign corporation, over (ii) the undistributed U.S. earnings of such controlled foreign corporation. (B) Undistributed earnings The term undistributed earnings means the earnings and profits of the