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 controlled foreign corporation described in section 959(c)(3), determined— (i) as of the close of the taxable year described in paragraph (1), (ii) without diminution by reason of distributions made during such taxable year, and (iii) without regard to this subsection. For purposes of this chapter, any determination with respect to the treatment of distributions described in clause (ii) shall be made after the application of this subsection to the earnings and profits described in the matter preceding clause (i). (C) Undistributed U.S. earnings The term undistributed U.S. earnings has the meaning given the term post-1986 undistributed U.S. earnings in section 245(a)(5), determined— (i) as of the close of the taxable year described in paragraph (1), and (ii) without regard to post-1986 each place it appears in the matter before subparagraph (A). (4) Acquisition date For purposes of this section, the term acquisition date means the date the covered entity completes the acquisition described in subsection (a)(2)(B)(i) (after the application of paragraph (2)(B)(i) of this subsection). . (b) Effective date The amendments made by this section shall apply with respect to taxable years ending after July 24, 2017.