,i #aacth ,,congress #ast ,session ,h4 ,r4 #fji ,,in ,,the ,,house ,,of ,,representatives ,february #ab1 #bjac ,mr4 ,blumenauer 7for himself1 ,mr4 ,markey1 ,ms4 ,schakowsky1 ,mr4 ,conyers1 ,ms4 ,pingree of ,maine1 ,ms4 ,norton1 ,ms4 ,mc,collum1 ,mr4 ,de,fazio1 ,ms4 ,slaughter1 ,mr4 ,nadler1 ,ms4 ,de,lauro1 ,mr4 ,moran1 ,mr4 ,grijalva1 ,mr4 ,polis1 ,ms4 ,tsongas1 ,mr4 ,langevin1 ,ms4 ,lee of ,california1 ,mr4 ,quigley1 ,mr4 ,cicilline1 ,ms4 ,speier1 ,mr4 ,van ,hollen1 ,mr4 ,mc,govern1 ,mr4 ,welch1 ,mr4 ,connolly1 ,mr4 ,honda1 ,mrs4 ,capps1 and ,mr4 ,waxman7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to repeal fossil fuel subsidies for large oil companies4 #a4 ,short title ,this ,act may be cited as the ,end ,big ,oil ,tax ,subsidies ,act of #bjac4 #b4 ,amortization of geological and geophysical expenditures 7a7 ,in general ,subparagraph 7,a7 of section #afg7;h77#e7 of the ,internal ,revenue ,code of #aihf is amended by striking major integrated oil company and inserting covered large oil company4 7b7 ,covered large oil company ,paragraph 7#e7 of section #afg7;h7 of such ,act is amended by redesignating subparagraph 7,b7 as subparagraph 7,c7 and by inserting after subparagraph 7,a7 the following new subparagraph3 7,b7 ,covered large oil company ,for purposes of this paragraph1 the term covered large oil company means a taxpayer which-- 7i7 is a major integrated oil company1 or 7ii7 has gross receipts in excess of #ej1jjj1jjj for the taxable year4 ,for purposes of clause 7ii71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 7c7 ,conforming amendment ,the heading for paragraph 7#e7 of section #afg7;h7 of such ,code is amended by inserting and other large taxpayers4 7d7 ,effective date ,the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjac4 #c4 ,producing oil and gas from marginal wells 7a7 ,in general ,section #de;,i of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7e7 ,exception for taxpayer who is not small1 independent oil and gas company 7#a7 ,in general ,subsection 7a7 shall not apply to any taxpayer which is not a small1 independent oil and gas company for the taxable year4 7#b7 ,aggregation rule ,for purposes of paragraph 7#a71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 7b7 ,effective date ,the amendment made by subsection 7a7 shall apply to credits determined for taxable years beginning after ,december #ca1 #bjac4 #d4 ,enhanced oil recovery credit 7a7 ,in general ,section #dc of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7f7 ,exception for taxpayer who is not small1 independent oil and gas company 7#a7 ,in general ,subsection 7a7 shall not apply to any taxpayer which is not a small1 independent oil and gas company for the taxable year4 7#b7 ,aggregation rule ,for purposes of paragraph 7#a71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 7b7 ,effective date ,the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjac4 #e4 ,intangible drilling and development costs in the case of oil and gas wells 7a7 ,in general ,subsection 7c7 of section #bfc 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 not a small1 independent oil and gas company1 determined by deeming all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb as #a person44 7b7 ,effective date ,the amendment made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjac4 #f4 ,percentage depletion 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 ,exception for taxpayer who is not small1 independent oil and gas company 7#a7 ,in general ,this section and section #faa shall not apply to any taxpayer which is not a small1 independent oil and gas company for the taxable year4 7#b7 ,aggregation rule ,for purposes of paragraph 7#a71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 7b7 ,conforming amendment ,section #fac;,a7c77#a7 of such ,code is amended by striking subsection 7d7 and inserting subsections 7d7 and 7f74 7c7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjac4 #g4 ,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 ,exception for taxpayer who is not small1 independent oil and gas company 7#a7 ,in general ,subsection 7a7 shall not apply to any taxpayer which is not a small1 independent oil and gas company for the taxable year4 7#b7 ,exception for qualified carbon dioxide disposed in secure geological storage ,paragraph 7#a7 shall not apply in the case of any qualified tertiary injectant expense paid or incurred for any tertiary injectant that is qualified carbon dioxide 7as defined in section #de,q7b77 which is disposed of by the taxpayer in secure geological storage 7as defined by section #de,q7d774 7#c7 ,aggregation rule ,for purposes of paragraph 7#a71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 7b7 ,effective date ,the amendment made by this section shall apply to expenses incurred after ,december #ca1 #bjac4 #h4 ,passive activity losses and credits limited 7a7 ,in general ,paragraph 7#c7 of section #dfi7;c7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7,c7 ,exception for taxpayer who is not small1 independent oil and gas company 7i7 ,in general ,subparagraph 7,a7 shall not apply to any taxpayer which is not a small1 independent oil and gas company for the taxable year4 7ii7 ,aggregation rule ,for purposes of clause 7i71 all persons treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as #a person4 4 #i4 ,income attributable to domestic production activities 7a7 ,in general ,section #aii of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7e7 ,exception for taxpayer who is not small1 independent oil and gas company ,subsection 7a7 shall not apply to the income derived from the production1 transportation1 or distribution of oil1 natural gas1 or any primary product 7within the meaning of subsection 7d77#i77 thereof by any taxpayer which for the taxable year is an oil and gas company which is not a small1 independent oil and gas company4 4 7b7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjac4 #aj4 ,prohibition on using last-in1 first-out accounting for major integrated oil companies 7a7 ,in general ,section #dgb of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7h7 ,major integrated oil companies ,notwithstanding any other provision of this section1 a major integrated oil company 7as defined in section #afg7;h77 may not use the method provided in subsection 7b7 in inventorying of any goods4 4 7b7 ,effective date and special rule 7#a7 ,in general ,the amendment made by subsection 7a7 shall apply to taxable years beginning after ,december #ca1 #bjac4 7#b7 ,change in method of accounting ,in the case of any taxpayer required by the amendment made by this section to change its method of accounting for its first taxable year beginning after the date of the enactment of this ,act-- 7,a7 such change shall be treated as initiated by the taxpayer1 7,b7 such change shall be treated as made with the consent of the ,secretary of the ,treasury1 and 7,c7 the net amount of the adjustments required to be taken into account by the taxpayer under section #dha of the ,internal ,revenue ,code of #aihf shall be taken into account ratably over a period 7not greater than #h taxable years7 beginning with such first taxable year4 #aa4 ,modifications of foreign tax credit rules applicable to 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 dual capacity taxpayers 7#a7 ,general rule ,notwithstanding any other provision of this chapter1 any amount paid or accrued by a dual capacity taxpayer to a foreign country or possession of the ,united ,states for any period with respect to combined foreign oil and gas income 7as defined in section #ijg7;b77#a77 shall not be considered a tax to the extent such amount exceeds the amount 7determined in accordance with regulations7 which would have been required to be paid if the taxpayer were not a dual capacity taxpayer4 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 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 ,december #ca1 #bjac4 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