,i #aacth ,,congress #ast ,session ,h4 ,r4 #bief ,,in ,,the ,,house ,,of ,,representatives ,august #a1 #bjac ,mr4 ,murphy of ,florida 7for himself1 ,mr4 ,blumenauer1 ,ms4 ,esty1 and ,mr4 ,barber7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means1 and in addition to the ,committee on ,natural ,resources1 for a period to be subsequently determined by the ,speaker1 in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned ,a ,,bill ,to eliminate unnecessary oil tax credits and subsidies for major oil companies to reduce the national debt4 #a4 ,short title ,this ,act may be cited as the ,end ,welfare for ,big ,oil ,act of #bjac4 ,i ,repeal of oil and gas subsidies ,a ,close big oil tax loopholes #aja4 ,modifications of foreign tax credit rules applicable to major integrated oil companies which are dual capacity taxpayers 7a7 ,in general ,section #ija of the ,internal ,revenue ,code of #aihf is amended by redesignating subsection 7n7 as subsection 7o7 and by inserting after subsection 7m7 the following new subsection3 7n7 ,special rules relating to major integrated oil companies which are dual capacity taxpayers 7#a7 ,general rule ,notwithstanding any other provision of this chapter1 any amount paid or accrued by a dual capacity taxpayer which is a major integrated oil company 7as defined in section #afg7;h77#e77;,b77 to a foreign country or possession of the ,united ,states for any period shall not be considered a tax-- 7,a7 if1 for such period1 the foreign country or possession does not impose a generally applicable income tax1 or 7,b7 to the extent such amount exceeds the amount 7determined in accordance with regulations7 which-- 7i7 is paid by such dual capacity taxpayer pursuant to the generally applicable income tax imposed by the country or possession1 or 7ii7 would be paid if the generally applicable income tax imposed by the country or possession were applicable to such dual capacity taxpayer4 ,nothing in this paragraph shall be construed to imply the proper treatment of any such amount not in excess of the amount determined under subparagraph 7,b74 7#b7 ,dual capacity taxpayer ,for purposes of this subsection1 the term dual capacity taxpayer means1 with respect to any foreign country or possession of the ,united ,states1 a person who-- 7,a7 is subject to a levy of such country or possession1 and 7,b7 receives 7or will receive7 directly or indirectly a specific economic benefit 7as determined in accordance with regulations7 from such country or possession4 7#c7 ,generally applicable income tax ,for purposes of this subsection-- 7,a7 ,in general ,the term generally applicable income tax means an income tax 7or a series of income taxes7 which is generally imposed under the laws of a foreign country or possession on income derived from the conduct of a trade or business within such country or possession4 7,b7 ,exceptions ,such term shall not include a tax unless it has substantial application1 by its terms and in practice1 to-- 7i7 persons who are not dual capacity taxpayers1 and 7ii7 persons who are citizens or residents of the foreign country or possession4 4 7b7 ,effective ,date 7#a7 ,in general ,the amendments made by this section shall apply to taxes paid or accrued in taxable years beginning after the date of the enactment of this ,act4 7#b7 ,contrary treaty obligations upheld ,the amendments made by this section shall not apply to the extent contrary to any treaty obligation of the ,united ,states4 #ajb4 ,limitation on section #aii deduction attributable to oil1 natural gas1 or primary products thereof 7a7 ,denial of deduction ,paragraph 7#d7 of section #aii7;c7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subparagraph3 7,e7 ,special rule for certain oil and gas income ,in the case of any taxpayer who is a major integrated oil company 7as defined in section #afg7;h77#e77;,b77 for the taxable year1 the term domestic production gross receipts shall not include gross receipts from the production1 transportation1 or distribution of oil1 natural gas1 or any primary product 7within the meaning of subsection 7d77#i77 thereof4 4 7b7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjac4 #ajc4 ,limitation on deduction for intangible drilling and development costs 7a7 ,in general ,section #bfc7;c7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new sentence3 ,this subsection shall not apply to amounts paid or incurred by a taxpayer in any taxable year in which such taxpayer is a major integrated oil company 7as defined in section #afg7;h77#e77;,b7744 7b7 ,effective date ,the amendment made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjac4 #ajd4 ,limitation on percentage depletion allowance for oil and gas wells 7a7 ,in general ,section #fac;,a of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7f7 ,application with respect to major integrated oil companies ,in the case of any taxable year in which the taxpayer is a major integrated oil company 7as defined in section #afg7;h77#e77;,b771 the allowance for percentage depletion shall be zero4 4 7b7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjac4 #aje4 ,limitation on deduction for tertiary injectants 7a7 ,in general ,section #aic of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7d7 ,application with respect to major integrated oil companies ,this section shall not apply to amounts paid or incurred by a taxpayer in any taxable year in which such taxpayer is a major integrated oil company 7as defined in section #afg7;h77#e77;,b774 4 7b7 ,effective date ,the amendment made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjac4 ,b ,outer ,continental ,shelf oil and natural gas #aaa4 ,repeal of outer ,continental ,shelf deep water and deep gas royalty relief 7a7 ,in general ,sections #cdd and #cde of the ,energy ,policy ,act of #bjje 7#db ,u4,s4,c4 #aeijd1 #aeije7 are repealed4 7b7 ,limitation on application ,the repeal under subsection 7a7 shall not affect the application of the repealed sections with respect to any lease sale for which a notice of sale is published before the date of enactment of this ,act4 ,,ii ,budgetary effects #bja4 ,deficit reduction ,the net amount of any savings realized as a result of the enactment of this ,act and the amendments made by this ,act 7after any expenditures authorized by this ,act and the amendments made by this ,act7 shall be deposited in the ,treasury and used for ,federal budget deficit reduction or1 if there is no ,federal budget deficit1 for reducing the ,federal debt in such manner as the ,secretary of the ,treasury considers appropriate4