,,ii  #aaeth ,,congress  #b;d ,session  
,s4 #chjd  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,december #ba1 
#bjah ,ms4 ,duckworth introduced the    
following bill2 which was read twice and
 referred to the ,committee on ,finance 
,a ,,bill  ,to reinstate the taxation of
 foreign oil related income1 and for    
other purposes4  #a4 ,treatment of      
foreign oil related income as subpart ,f
 income  7a7 ,in general ,section       
#ied7;a7 of the ,internal ,revenue ,code
 of #aihf is amended by striking and at 
the end of paragraph 7#b71 by striking  
the period at the end of paragraph 7#c7 
and inserting 1 and1 and by adding at   
the end the following new paragraph3    
7#d7 the foreign base company oil       
related income for the taxable year     
7determined under subsection 7g7 and    
reduced as provided in subsection       
7b77#e774  4  7b7 ,foreign base company 
oil related income ,section #ied of the 
,internal ,revenue ,code of #aihf is    
amended by inserting after subsection   

7e7 the following new subsection3  7g7  
,foreign base company oil related income
 ,for purposes of this section-- 7#a7   
,in general ,except as otherwise        
provided in this subsection1 the term   
foreign base company oil related income 
means foreign oil related income 7within
 the meaning of paragraphs 7#b7 and 7#c7
 of section #ijg7;c77 other than income 
derived from a source within a foreign  
country in connection with--  7,a7 oil  
or gas which was extracted from an oil  
or gas well located in such foreign     
country1 or  7,b7 oil1 gas1 or a primary
 product of oil or gas which is sold by 
the foreign corporation or a related    
person for use or consumption within    
such country or is loaded in such       
country on a vessel or aircraft as fuel 
for such vessel or aircraft4  ,such term
 shall not include any foreign personal 
holding company income 7as defined in   
subsection 7c774  7#b7 ,paragraph 7#a7  
applies only where corporation has      
produced #a1jjj barrels per day or more 

7,a7 ,in general ,the term foreign base 
company oil related income shall not    
include any income of a foreign         
corporation if such corporation is not a
 large oil producer for the taxable     
year4  7,b7 ,large oil producer ,for    
purposes of subparagraph 7,a71 the term 
large oil producer means any corporation
 if1 for the taxable year or for the    
preceding taxable year1 the average     
daily production of foreign crude oil   
and natural gas of the related group    
which includes such corporation equaled 
or exceeded #a1jjj barrels4  7,c7       
,related group ,the term related group  
means a group consisting of the foreign 
corporation and any other person who is 
a related person with respect to such   
corporation4  7,d7 ,average daily       
production of foreign crude oil and     
natural gas ,for purposes of this       
paragraph1 the average daily production 
of foreign crude oil or natural gas of  
any related group for any taxable year  
7and the conversion of cubic feet of    

natural gas into barrels7 shall be      
determined under rules similar to the   
rules of section #fac;,a except that    
only crude oil or natural gas from a    
well located outside the ,united ,states
 shall be taken into account4  4  7c7   
,conforming amendments  7#a7 ,section   
#ieb7;c77#a77;,b77iii7 of the ,internal 
,revenue ,code of #aihf is amended by   
redesignating subclauses 7,i7 through   
7,,iv7 as subclause 7,,ii7 through 7,v71
 respectively1 and by inserting before  
subclause 7,,ii7 7as so redesignated7   
the following3  7,i7 foreign base       
company oil related income1  4  7#b7    
,section #ied7;b7 of such ,code is      
amended--  7,a7 by inserting at the end 
of paragraph 7#d7 the following3 ,the   
preceding sentence shall not apply to   
foreign base company oil-related income 
described in subsection 7a77#d741  7,b7 
by striking and the foreign base company
 services income in paragraph 7#e7 and  
inserting the foreign base company      
services income1 and the foreign base   

company oil related income1 and  7,c7 by
 adding at the end the following new    
paragraph3  7#f7 ,foreign base company  
oil related income not treated as       
another kind of base company income     
,income of a corporation which is       
foreign base company oil related income 
shall not be considered foreign base    
company income of such corporation under
 paragraph 7#b7 or 7#c7 of subsection   
7a74  4  7d7 ,effective date ,the       
amendments made by this section shall   
apply to taxable years of foreign       
corporations beginning after the date of
 the enactment of this ,act and to      
taxable years of ,united ,states        
shareholders ending with or within which
 such taxable years of foreign          
corporations end4