In continuing efforts to dissuade U.S. companies from inverting abroad, U.S. Senators Richard Durbin and Sherrod Brown have drafted the so called "Pay What You Owe Before You Go Act." If enacted, the legislation would require inverting U.S. companies to pay taxes on unrepatriated foreign earnings held prior to the completion of the inversion by adding such earning to the U.S. company's subpart F income in the last tax year ending before the date of acquisition by a foreign entity. This would …