,,ii #aaith ,,congress #ast ,session ,s4 #bddd ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,july #bd1 #bjbe ,mr4 ,sanders 7for himself1 ,ms4 ,warren1 ,mr4 ,merkley1 ,mr4 ,welch1 ,mr4 ,van ,hollen1 ,mr4 ,markey1 and ,mr4 ,booker7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to eliminate certain subsidies for fossil-fuel production4 #a4 ,short title ,this ,act may be cited as the ,end ,polluter ,welfare ,act of #bjbe4 #b4 ,table of contents ,the table of contents for this ,act is as follows3 ,sec4 #a4 ,short title4 ,sec4 #b4 ,table of contents4 ,,title ,i--,elimination of fossil fuel subsidies ,sec4 #aja4 ,definition of fossil fuel4 ,sec4 #ajb4 ,royalty relief4 ,sec4 #ajc4 ,royalties under ,mineral ,leasing ,act4 ,sec4 #ajd4 ,offshore oil and gas royalty rate4 ,sec4 #aje4 ,elimination of interest payments for royalty overpayments4 ,sec4 #ajf4 ,removal of limits on liability for offshore facilities and pipeline operators4 ,sec4 #ajg4 ,restrictions on use of appropriated funds by international financial institutions for projects that support fossil fuel4 ,sec4 #ajh4 ,office of ,fossil ,energy and ,carbon ,management4 ,sec4 #aji4 ,loan ,programs ,office of the ,department of ,energy4 ,sec4 #aaj4 ,,usda assistance for carbon capture and storage systems4 ,sec4 #aaa4 ,advanced ,research ,projects ,agency--,energy4 ,sec4 #aab4 ,incentives for innovative technologies4 ,sec4 #aac4 ,rural ,utility ,service loan guarantees4 ,sec4 #aad4 ,prohibition on use of funds by the ,united ,states ,international ,development ,finance ,corporation or the ,export-,import ,bank of the ,united ,states for financing projects1 transactions1 or other activities that support fossil fuel4 ,sec4 #aae4 ,transportation funds for grants1 loans1 loan guarantees1 and other direct assistance4 ,sec4 #aaf4 ,elimination of exclusion of certain lenders as owners or operators under ,,cercla4 ,,title ,,ii--,amendments to ,internal ,revenue ,code of #aihf ,sec4 #bja4 ,termination of various tax expenditures relating to fossil fuels4 ,sec4 #bjb4 ,termination of certain deductions and credits related to fossil fuels4 ,sec4 #bjc4 ,uniform seven-year amortization for geological and geophysical expenditures4 ,sec4 #bjd4 ,natural gas gathering lines treated as #ae-year property4 ,sec4 #bje4 ,termination of last-in1 first-out method of inventory for oil1 natural gas1 and coal companies4 ,sec4 #bjf4 ,repeal of percentage depletion for coal and hard mineral fossil fuels4 ,sec4 #bjg4 ,termination of capital gains treatment for royalties from coal4 ,sec4 #bjh4 ,modifications of foreign tax credit rules applicable to oil and gas industry taxpayers receiving specific economic benefits4 ,sec4 #bji4 ,increase in oil spill liability trust fund financing rate4 ,sec4 #baj4 ,application of certain environmental taxes to synthetic crude oil4 ,sec4 #baa4 ,denial of deduction for removal costs and damages for certain oil spills4 ,sec4 #bab4 ,tax on crude oil and natural gas produced from the outer ,continental ,shelf in the ,gulf of ,mexico4 ,sec4 #bac4 ,repeal of corporate income tax exemption for publicly traded partnerships with qualifying income and gains from activities relating to fossil fuels4 ,sec4 #bad4 ,amortization of qualified tertiary injectant expenses4 ,sec4 #bae4 ,amortization of development expenditures4 ,sec4 #baf4 ,amortization of certain mining exploration expenditures4 ,sec4 #bag4 ,amortization of intangible drilling and development costs in the case of oil and gas wells4 ,sec4 #bah4 ,increase in excise tax rate for funding of ,black ,lung ,disability ,trust ,fund4 ,sec4 #bai4 ,elimination of renewable electricity production credit eligibility for refined coal4 ,sec4 #bbj4 ,treatment of foreign oil related income as subpart ,f income4 ,sec4 #bba4 ,repeal of exclusion of foreign oil and gas extraction income from the determination of tested income4 ,sec4 #bbb4 ,termination of credit for carbon oxide sequestration4 ,sec4 #bbc4 ,eliminate drawbacks on petroleum taxes4 ,sec4 #bbd4 ,modifying clean hydrogen production credit4 ,,title ,,iii--,repeal recent fossil fuel subsidy legislation ,sec4 #cja4 ,,builder ,act4 ,sec4 #cjb4 ,inflation ,reduction ,act4 ,sec4 #cjc4 ,one ,big ,beautiful ,bill ,act4 ,sec4 #cjd4 ,waste emissions charge rule4 ,,title ,,iv--,elimination of other fossil fuel subsidies ,sec4 #dja4 ,study and elimination of additional fossil fuel subsidies4 ,i ,elimination of fossil fuel subsidies #aja4 ,definition of fossil fuel ,in this ,act1 the term fossil fuel means coal1 petroleum1 natural gas1 or any derivative of coal1 petroleum1 or natural gas that is used for fuel4 #ajb4 ,royalty relief 7a7 ,in general 7#a7 ,outer ,continental ,shelf ,lands ,act ,section #h7;a77#c7 of the ,outer ,continental ,shelf ,lands ,act 7#dc ,u4,s4,c4 #accg7;a77#c77 is amended-- 7,a7 by striking subparagraph 7,b72 and 7,b7 by redesignating subparagraph 7,c7 as subparagraph 7,b74 7#b7 ,energy ,policy ,act of #bjje 7,a7 ,incentives for natural gas production from deep wells in the shallow waters of the ,gulf of ,mexico ,section #cdd of the ,energy ,policy ,act of #bjje 7#db ,u4,s4,c4 #aeijd7 is repealed4 7,b7 ,deep water production ,section #cde of the ,energy ,policy ,act of #bjje 7#db ,u4,s4,c4 #aeije7 is repealed4 7#c7 ,clerical amendment ,the table of contents in section #a7;b7 of the ,energy ,policy ,act of #bjje 7,public ,law #aji-eh2 #aai ,stat4 #eif7 is amended by striking the items relating to sections #cdd and #cde4 7b7 ,future provisions ,notwithstanding any other provision of law1 royalty relief shall not be permitted under a lease issued under section #h of the ,outer ,continental ,shelf ,lands ,act 7#dc ,u4,s4,c4 #accg74 #ajc4 ,royalties under ,mineral ,leasing ,act 7a7 ,coal leases ,section #g7;a7 of the ,mineral ,leasing ,act 7#cj ,u4,s4,c4 #bjg7;a77 is amended in the fourth sentence by striking #aba_/b per centum and inserting #ahc_/d percent4 7b7 ,leases on land on which oil or natural gas is discovered ,section #ad of the ,mineral ,leasing ,act 7#cj ,u4,s4,c4 #bbc7 is amended in the fourth sentence by striking #aba_/b per centum and inserting #ahc_/d percent4 7c7 ,leases on land known or believed ,to contain oil or natural gas ,section #ag of the ,mineral ,leasing ,act 7#cj ,u4,s4,c4 #bbf7 is amended-- 7#a7 in subsection 7b7-- 7,a7 in paragraph 7#a77;,a71 in the fifth sentence1 by striking #afb_/c percent each place it appears and inserting #ahc_/d percent2 and 7,b7 in paragraph 7#b77;,a77ii71 by striking #afb_/c per centum and inserting not less than #ahc_/d percent2 7#b7 in subsection 7l71 by striking #afb_/c per centum each place it appears and inserting #ahc_/d percent2 and 7#c7 in subsection 7n77#a77;,c71 by striking #afb_/c per centum and inserting not less than #ahc_/d percent4 #ajd4 ,offshore oil and gas royalty rate ,section #h7;a77#a7 of the ,outer ,continental ,shelf ,lands ,act 7#dc ,u4,s4,c4 #accg7;a77#a77 is amended by striking #afb_/c percent1 but not more than #ahc_/d percent1 during the #aj-year period beginning on the date of enactment of the ,act titled ,an ,act to provide for reconciliation pursuant to title ,,ii of ,s4 ,con4 ,res4 #ad1 and not less than #afb_/c percent thereafter1 each place it appears and inserting #ahc_/d percent14 #aje4 ,elimination of interest payments for royalty overpayments ,section #aaa of the ,federal ,oil and ,gas ,royalty ,management ,act of #aihb 7#cj ,u4,s4,c4 #agba7 is amended by adding at the end the following3 7k7 ,payment of interest ,interest shall not be paid on any overpayment4 4 #ajf4 ,removal of limits on liability for offshore facilities and pipeline operators ,section #ajjd7;a7 of the ,oil ,pollution ,act of #aiij 7#cc ,u4,s4,c4 #bgjd7;a77 is amended-- 7#a7 in paragraph 7#c71 by striking plus #ge1jjj1jjj2 and and inserting and the liability of the responsible party under section #ajjb22 7#b7 in paragraph 7#d7-- 7,a7 by inserting 7except an onshore pipeline transporting diluted bitumen1 bituminous mixtures1 or any oil manufactured from bitumen7 after for any onshore facility2 and 7,b7 by striking the period at the end and inserting 2 and2 and 7#c7 by adding at the end the following3 7#e7 for any onshore facility transporting diluted bitumen1 bituminous mixtures1 or any oil manufactured from bitumen1 the liability of the responsible party under section #ajjb4 4 #ajg4 ,restrictions on use of appropriated funds by international financial institutions for projects that support fossil fuel 7a7 ,definition of international financial institution ,in this section1 the term international financial institution means-- 7#a7 each institution described in section #agja7;c7 of the ,international ,financial ,institutions ,act 7#bb ,u4,s4,c4 #bfbr7c772 and 7#b7 the ,north ,american ,development ,bank4 7b7 ,rescission of unobligated funds 7#a7 ,in general ,of the unobligated balance of amounts appropriated or otherwise made available for a contribution of the ,united ,states to an international financial institution1 an amount specified in paragraph 7#b7 shall be rescinded if the institution provides support for a project that supports the production or use of fossil fuels4 7#b7 ,amount specified ,the amount specified in this paragraph is an amount the ,secretary of the ,treasury determines to be equivalent to the amount of support provided by an international financial institution described in paragraph 7#a7 for a project that supports the production or use of fossil fuels4 7c7 ,prohibition on use of future funds ,no amounts appropriated or otherwise made available for a contribution of the ,united ,states to an international financial institution may be provided to the institution unless the institution agrees to not use the amount to provide support for any project that supports the production or use of fossil fuels4 #ajh4 ,office of ,fossil ,energy and ,carbon ,management 7a7 ,termination of authority ,notwithstanding any other provision of law1 the authority of the ,secretary of ,energy to carry out the ,office of ,fossil ,energy and ,carbon ,management of the ,department of ,energy is terminated4 7b7 ,rescission ,notwithstanding any other provision of law-- 7#a7 all amounts made available for the ,office of ,fossil ,energy and ,carbon ,management that remain unobligated as of the date of enactment of this ,act are rescinded2 and 7#b7 no amounts made available after the date of enactment of this ,act for the ,office of ,fossil ,energy and ,carbon ,management shall be expended1 other than such amounts as are necessary to cover costs incurred in terminating ongoing research of the ,office of ,fossil ,energy and ,carbon ,management1 as determined by the ,secretary of ,energy1 in consultation with other appropriate ,federal agencies4 #aji4 ,loan ,programs ,office of the ,department of ,energy 7a7 ,prohibition ,subject to subsection 7b71 none of the funds made available to the ,loan ,programs ,office of the ,department of ,energy shall be used to carry out any project that supports fossil fuel1 carbon capture1 or hydrogen4 7b7 ,exception ,the prohibition on the use of funds for hydrogen projects under subsection 7a7 does not apply to projects that support qualified clean hydrogen 7as defined in section #de,v7c7 of the ,internal ,revenue ,code of #aihf 7as amended by section #bbd7;a77#c7774 #aaj4 ,,usda assistance for carbon capture and storage systems ,section #ijjc7;j77#a7 of the ,farm ,security and ,rural ,investment ,act of #bjjb 7#g ,u4,s4,c4 #hajc7;j77#a77 is amended-- 7#a7 by inserting and after renewable energy systems12 and 7#b7 by striking and carbon capture and storage systems14 #aaa4 ,advanced ,research ,projects ,agency--,energy ,none of the funds made available to the ,advanced ,research ,projects ,agency--,energy shall be used to carry out any project that supports fossil fuel4 #aab4 ,incentives for innovative technologies 7a7 ,in general ,section #agjc of the ,energy ,policy ,act of #bjje 7#db ,u4,s4,c4 #afeac7 is amended-- 7#a7 in subsection 7b7-- 7,a7 by striking paragraphs 7#b7 and 7#aj72 and 7,b7 by redesignating paragraphs 7#c71 7#d71 7#e71 7#f71 7#g71 7#h71 7#i71 7#aa71 7#ab71 and 7#ac7 as paragraphs 7#b71 7#c71 7#d71 7#e71 7#f71 7#g71 7#h71 7#i71 7#aj71 and 7#aa7 respectively2 7#b7 by striking subsection 7c72 and 7#c7 by redesignating subsections 7d7 through 7f7 as subsections 7c7 through 7e71 respectively4 7b7 ,conforming amendment ,section #agjd of the ,energy ,policy ,act of #bjje 7#db ,u4,s4,c4 #afead7 is amended-- 7#a7 by striking subsection 7b72 and 7#b7 by redesignating subsection 7c7 as subsection 7b74 #aac4 ,rural ,utility ,service loan guarantees ,notwithstanding any other provision of law1 the ,secretary of ,agriculture may not make a loan under title ,,iii of the ,rural ,electrification ,act of #aicf 7#g ,u4,s4,c4 #ica et seq47 to an applicant for the purpose of carrying out any project that will use fossil fuel4 #aad4 ,prohibition on use of funds by the ,united ,states ,international ,development ,finance ,corporation or the ,export-,import ,bank of the ,united ,states for financing projects1 transactions1 or other activities that support fossil fuel ,notwithstanding any other provision of law1 no amounts appropriated or otherwise made available for the ,united ,states ,international ,development ,finance ,corporation1 the ,export-,import ,bank of the ,united ,states1 the ,united ,states ,trade and ,development ,agency1 the ,united ,states ,agency for ,international ,development1 or the ,millennium ,challenge ,corporation that are available for obligation on or after the date of enactment of this ,act may be obligated or expended to support any project1 transaction1 or other activity that supports the production or use of fossil fuels4 #aae4 ,transportation funds for grants1 loans1 loan guarantees1 and other direct assistance ,notwithstanding any other provision of law1 any amounts made available to the ,department of ,transportation 7including the ,federal ,railroad ,administration7 may not be used to award any grant1 loan1 loan guarantee1 or provide any other direct assistance to any rail facility or port project that transports fossil fuel4 #aaf4 ,elimination of exclusion of certain lenders as owners or operators under ,,cercla ,section #aja7bj77;,f7 of the ,comprehensive ,environmental ,response1 ,compensation1 and ,liability ,act of #aihj 7#db ,u4,s4,c4 #ifja7bj77;,f77 is amended by adding at the end the following3 7iii7 ,ineligible lenders ,the exclusions under clauses 7i7 and 7ii7 shall not apply to a person that is a lender that is-- 7,i7 an investment company registered under the ,investment ,company ,act of #aidj 7#ae ,u4,s4,c4 #hj;a-#a et seq471 an investment adviser 7as defined in section #bjb7;a7 of the ,investment ,advisers ,act of #aidj 7#ae ,u4,s4,c4 #hj;b-#b7;a7771 or a broker or dealer 7as those terms are defined in section #c7;a7 of the ,securities ,exchange ,act of #aicd 7#ae ,u4,s4,c4 #gh;c7a777 with #bej1jjj1jjj1jjj or more in assets under management2 or 7,,ii7 a bank holding company 7as defined in section #b of the ,bank ,holding ,company ,act of #aief 7#ab ,u4,s4,c4 #ahda77 with #aj1jjj1jjj1jjj or more in total consolidated assets4 4 ,,ii ,amendments to ,internal ,revenue ,code of #aihf #bja4 ,termination of various tax expenditures relating to fossil fuels 7a7 ,in general ,subchapter ,c of chapter #hj of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #ghge4 ,termination of certain provisions relating to fossil-fuel incentives 7a7 ,in general ,the following provisions shall not apply to taxable years beginning after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe3 7#a7 ,section #dc 7relating to enhanced oil recovery credit74 7#b7 ,section #de;,i 7relating to credit for producing oil and natural gas from marginal wells74 7#c7 ,section #dfa7;i77#b7 7relating to special rule for spudding of oil or natural gas wells74 7#d7 ,section #dfi7;c77#c77;,a7 7relating to working interests in oil and natural gas property74 7#e7 ,section #fac;,a 7relating to limitations on percentage depletion in case of oil and natural gas wells74 7b7 ,provisions relating to property ,the following provisions shall not apply to property placed in service after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe3 7#a7 ,section #afh7;e77#c77;,c77iii7 7relating to classification of certain property74 7#b7 ,section #afi 7relating to amortization of pollution control facilities7 with respect to any atmospheric pollution control facility4 7c7 ,provisions relating to costs and expenses ,the following provisions shall not apply to costs or expenses paid or incurred after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe3 7#a7 ,section #agi;,b 7relating to deduction for capital costs incurred in complying with ,environmental ,protection ,agency sulfur regulations74 7#b7 ,section #dfh 7relating to special rules for mining and solid waste reclamation and closing costs74 7d7 ,allocated credits ,no new credits shall be certified under section #dh;,a 7relating to qualifying advanced coal project credit7 after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 7e7 ,arbitrage bonds ,section #adh7;b77#d7 7relating to safe harbor for prepaid natural gas7 shall not apply to obligations issued after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7b7 ,conforming amendments 7#a7 ,section #fac7;d7 of the ,internal ,revenue ,code of #aihf is amended by striking ,except as provided in section #fac;,a1 in the case and inserting ,in the case4 7#b7 ,the table of sections for subchapter ,c of chapter #ij of such ,code is amended by adding at the end the following new item3 ,sec4 #ghge4 ,termination of certain provisions relating to fossil-fuel incentives4 4 #bjb4 ,termination of certain deductions and credits related to fossil fuels 7a7 ,special allowance for certain property ,section #afh7k7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7#aa7 ,fossil fuel property 7,a7 ,in general ,this subsection shall not apply with respect to any property which is primarily used for fossil fuel activities and is placed in service during any taxable year beginning after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 7,b7 ,fossil fuel activities ,for purposes of this paragraph1 the term fossil fuel activities means the exploration1 development1 mining or production1 processing1 refining1 transportation 7including pipelines transporting gas1 oil1 or products thereof71 distribution1 or marketing of coal1 petroleum1 natural gas1 or any derivative of coal1 petroleum1 or natural gas that is used for fuel4 7,c7 ,exception ,the property described in subparagraph 7,a7 shall not include any motor vehicle service station or convenience store which does not qualify as a retail motor fuels outlet under subsection 7e77#c77;,e77iii74 4 7b7 ,qualified business income ,section #aii;,a7c77#c77;,b7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7viii7 ,any item of gain or loss derived from fossil fuel activities 7as defined in section #afh7k77#aa77;,b77 during any taxable year beginning after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7c7 ,credit for increasing research activities ,section #da7;d77#d7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7,i7 ,fossil fuel activities ,any research related to fossil fuel activities 7as defined in section #afh7k77#aa77;,b77 which is conducted after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7d7 ,foreign-,derived intangible income ,subclause 7,v7 of section #bej7;b77#c77;,a77i7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7,v7 any income derived from fossil fuel activities 7as defined in section #afh7k77#aa77;,b77 during any taxable year beginning after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe1 and 4 7e7 ,exchange of real property held for productive use or investment ,section #ajca7;a77#b7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7#b7 ,exceptions ,this subsection shall not apply to-- 7,a7 any exchange of real property held primarily for sale1 or 7,b7 any exchange of real property which-- 7i7 is used for fossil fuel activities 7as defined in section #afh7k77#aa77;,b771 and 7ii7 occurs after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 #bjc4 ,uniform seven-year amortization for geological and geophysical expenditures 7a7 ,in general ,section #afg7;h7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking #bd-month period each place it appears in paragraphs 7#a7 and 7#d7 and inserting #hd-month period1 7#b7 by striking paragraph 7#b7 and inserting the following3 7#b7 ,mid-month convention ,for purposes of paragraph 7#a71 any payment paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month4 1 and 7#c7 by striking paragraph 7#e74 7b7 ,effective date ,the amendments made by this section shall apply to amounts paid or incurred after the date of the enactment of this ,act4 #bjd4 ,natural gas gathering lines treated as #ae-year property 7a7 ,in general ,section #afh7;e77#c77;,e7 of the ,internal ,revenue ,code of #aihf is amended by striking and at the end of clause 7vi71 by striking the period at the end of clause 7vii7 and inserting 1 and1 and by adding at the end the following new clause3 7viii7 any natural gas gathering line the original use of which commences with the taxpayer after the date of the enactment of this clause4 4 7b7 ,alternative system ,the table contained in section #afh7;g77#c77;,b7 of the ,internal ,revenue ,code of #aihf is amended by inserting after the item relating to subparagraph 7,e77vii7 the following new item3 7,e77viii7 #bb 4 7c7 ,conforming amendment ,clause 7iv7 of section #afh7;e77#c77;,c7 of the ,internal ,revenue ,code of #aihf is amended by inserting and on or before the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe after ,april #aa1 #bjje4 7d7 ,effective date 7#a7 ,in general ,the amendments made by this section shall apply to property placed in service on and after the date of the enactment of this ,act4 7#b7 ,exception ,the amendments made by this section shall not apply to any property with respect to which the taxpayer or a related party has entered into a binding contract for the construction thereof on or before the date of the introduction of this ,act1 or1 in the case of self-constructed property1 has started construction on or before such date4 #bje4 ,termination of last-in1 first-out method of inventory for oil1 natural gas1 and coal 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 ,termination for oil1 natural gas1 and coal companies ,subsection 7a7 shall not apply to any taxpayer that is in the trade or business of the production1 refining1 processing1 transportation1 or distribution of oil1 natural gas1 or coal for any taxable year beginning after the date of enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7b7 ,additional termination ,section #dgc of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7h7 ,termination for oil1 natural gas1 and coal companies ,this section shall not apply to any taxpayer that is in the trade or business of the production1 refining1 processing1 transportation1 or distribution of oil1 natural gas1 or coal for any taxable year beginning after the date of enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7c7 ,change in method of accounting ,in the case of any taxpayer required by the amendments made by this section to change its method of accounting for its first taxable year beginning after the date of enactment of this ,act-- 7#a7 such change shall be treated as initiated by the taxpayer1 and 7#b7 such change shall be treated as made with the consent of the ,secretary of the ,treasury4 7d7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after the date of enactment of this ,act4 #bjf4 ,repeal of percentage depletion for coal and hard mineral fossil fuels 7a7 ,in general ,section #fac of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7f7 ,termination with respect to coal and hard mineral fossil fuels ,in the case of coal1 lignite1 and oil shale 7other than oil shale described in subsection 7b77#e771 the allowance for depletion shall be computed without reference to this section for any taxable year beginning after the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7b7 ,conforming amendments 7#a7 ,coal and lignite ,section #fac7;b77#d7 of the ,internal ,revenue ,code of #aihf is amended by striking coal1 lignite14 7#b7 ,oil shale ,section #fac7;b77#b7 of such ,code is amended to read as follows3 7#b7 #ae percent ,if1 from deposits in the ,united ,states1 gold1 silver1 copper1 and iron ore4 4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after the date of the enactment of this ,act4 #bjg4 ,termination of capital gains treatment for royalties from coal 7a7 ,in general ,subsection 7c7 of section #fca of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking coal 7including lignite71 or iron ore and inserting iron ore1 7#b7 by striking coal or iron ore each place it appears and inserting iron ore1 7#c7 by striking iron ore or coal each place it appears and inserting iron ore1 and 7#d7 by striking coal or in the heading4 7b7 ,conforming amendments 7#a7 ,the heading of section #fca of the ,internal ,revenue ,code of #aihf is amended by striking 1 coal14 7#b7 ,section #abca7;b77#b7 of such ,code is amended by striking 1 coal14 7c7 ,effective date ,the amendments made by this section shall apply to dispositions after the date of the enactment of this ,act4 #bjh4 ,modifications of foreign tax credit rules applicable to oil and gas industry taxpayers receiving specific economic benefits 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 to a foreign country or possession of the ,united ,states for any period by a dual capacity taxpayer which is in the trade or business of the production1 refining1 processing1 transportation1 or distribution of fossil fuel 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 no amount other than the amount required to be paid by such taxpayer under the generally applicable income tax imposed by the country or possession were paid or accrued by 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-- 7,i7 citizens or residents of the foreign country or possession1 or 7,,ii7 organized or incorporated under the laws of the foreign country or possession4 7#d7 ,fossil fuel ,for purposes of this subsection1 the term fossil fuel means coal1 petroleum1 natural gas1 or any derivative of coal1 petroleum1 or natural gas that is used for fuel4 4 7b7 ,effective date ,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 7c7 ,special rule for treaties ,notwithstanding sections #hid or #gheb7;d7 of the ,internal ,revenue ,code of #aihf1 the amendments made by this section shall apply without regard to any treaty obligation of the ,united ,states4 #bji4 ,increase in oil spill liability trust fund financing rate 7a7 ,in general ,section #dfaa of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 in subsection 7c77#b77;,b7-- 7,a7 in clause 7i71 by striking and at the end1 7,b7 in clause 7ii71 by striking the period at the end and inserting 1 and1 and 7,c7 by adding at the end the following3 7iii7 in the case of crude oil received or petroleum products entered after ,december #ca1 #bjbe1 #aj cents a barrel4 1 and 7#b7 by striking subsection 7f7 and inserting the following3 7f7 ,application of ,oil ,spill ,liability ,trust ,fund financing rate ,the ,oil ,spill ,liability ,trust ,fund financing rate under subsection 7c7 shall apply on and after ,april #a1 #bjjf1 or if later1 the date which is #cj days after the last day of any calendar quarter for which the ,secretary estimates that1 as of the close of that quarter1 the unobligated balance in the ,oil ,spill ,liability ,trust ,fund is less than #b1jjj1jjj1jjj4 4 7b7 ,effective date ,the amendments made by this section shall apply to crude oil received and petroleum products entered after ,december #ca1 #bjbe4 #baj4 ,application of certain environmental taxes to synthetic crude oil 7a7 ,in general ,paragraph 7#a7 of section #dfab7;a7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7#a7 ,crude oil 7,a7 ,in general ,the term crude oil includes crude oil condensates1 natural gasoline1 and synthetic crude oil4 7,b7 ,synthetic crude oil ,for purposes of subparagraph 7,a71 the term synthetic crude oil means-- 7i7 any bitumen and bituminous mixtures1 7ii7 any oil derived from bitumen and bituminous mixtures 7including oil derived from tar sands71 7iii7 any liquid fuel derived from coal1 and 7iv7 any oil derived from kerogen-bearing sources 7including oil derived from oil shale74 4 7b7 ,regulatory authority ,to address other types of crude oil and petroleum products ,subsection 7a7 of section #dfab of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7#aj7 ,regulatory authority to address other types of crude oil and petroleum products ,under such regulations as the ,secretary may prescribe1 the ,secretary may include as crude oil or as a petroleum product subject to tax under section #dfaa1 any fuel feedstock or finished fuel product customarily transported by pipeline1 vessel1 railcar1 or tanker truck if the ,secretary determines that-- 7,a7 the classification of such fuel feedstock or finished fuel product is consistent with the definition of oil under the ,oil ,pollution ,act of #aiij1 and 7,b7 such fuel feedstock or finished fuel product is produced in sufficient commercial quantities as to pose a significant risk of hazard in the event of a discharge4 4 7c7 ,technical amendment ,paragraph 7#b7 of section #dfab7;a7 of the ,internal ,revenue ,code of #aihf is amended by striking from a well located4 7d7 ,effective date ,the amendments made by this section shall apply to oil and petroleum products received or entered during calendar quarters beginning more than #fj days after the date of the enactment of this ,act4 #baa4 ,denial of deduction for removal costs and damages for certain oil spills 7a7 ,in general ,section #afb7;f7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by redesignating paragraph 7#e7 as paragraph 7#f71 and 7#b7 by inserting after paragraph 7#d7 the following3 7#e7 ,expenses for removal costs and damages relating to certain oil spill liability ,notwithstanding paragraphs 7#b7 and 7#c71 no deduction shall be allowed under this chapter for any costs or damages for which the taxpayer is liable under section #ajjb of the ,oil ,pollution ,act of #aiij 7#cc ,u4,s4,c4 #bgjb7 4 7b7 ,effective date ,the amendments made by this section shall apply with respect to any liability arising in taxable years ending after the date of the enactment of this ,act4 #bab4 ,tax on crude oil and natural gas produced from the outer ,continental ,shelf in the ,gulf of ,mexico 7a7 ,in general ,subtitle ,e of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new chapter3 #ef ,tax on severance of crude oil and natural gas from the outer ,continental ,shelf in the ,gulf of ,mexico ,sec4 #eija4 ,imposition of tax4 ,sec4 #eijb4 ,taxable crude oil or natural gas and removal price4 ,sec4 #eijc4 ,special rules and definitions4 #eija4 ,imposition of tax 7a7 ,in general ,in addition to any other tax imposed under this title1 there is hereby imposed a tax equal to #ac percent of the removal price of any taxable crude oil or natural gas removed from the premises during any taxable period4 7b7 ,credit for ,federal royalties paid 7#a7 ,in general ,there shall be allowed as a credit against the tax imposed by subsection 7a7 with respect to the production of any taxable crude oil or natural gas an amount equal to the aggregate amount of royalties paid under ,federal law with respect to such production4 7#b7 ,limitation ,the aggregate amount of credits allowed under paragraph 7#a7 to any taxpayer for any taxable period shall not exceed the amount of tax imposed by subsection 7a7 for such taxable period4 7c7 ,tax paid by producer ,the tax imposed by this section shall be paid by the producer of the taxable crude oil or natural gas4 #eijb4 ,taxable crude oil or natural gas and removal price 7a7 ,taxable crude oil or natural gas ,for purposes of this chapter1 the term taxable crude oil or natural gas means crude oil or natural gas which is produced from ,federal submerged lands on the outer ,continental ,shelf in the ,gulf of ,mexico pursuant to a lease entered into with the ,united ,states which authorizes the production4 7b7 ,removal price ,for purposes of this chapter-- 7#a7 ,in general ,except as otherwise provided in this subsection1 the term removal price means-- 7,a7 in the case of taxable crude oil1 the amount for which a barrel of such crude oil is sold1 and 7,b7 in the case of taxable natural gas1 the amount per #a1jjj cubic feet for which such natural gas is sold4 7#b7 ,sales between related persons ,in the case of a sale between related persons1 the removal price shall not be less than the constructive sales price for purposes of determining gross income from the property under section #fac4 7#c7 ,oil or natural gas removed from property before sale ,if crude oil or natural gas is removed from the property before it is sold1 the removal price shall be the constructive sales price for purposes of determining gross income from the property under section #fac4 7#d7 ,refining begun on property ,if the manufacture or conversion of crude oil into refined products begins before such oil is removed from the property-- 7,a7 such oil shall be treated as removed on the day such manufacture or conversion begins1 and 7,b7 the removal price shall be the constructive sales price for purposes of determining gross income from the property under section #fac4 7#e7 ,property ,the term property has the meaning given such term by section #fad4 #eijc4 ,special rules and definitions 7a7 ,administrative requirements 7#a7 ,withholding and deposit of tax ,the ,secretary shall provide for the withholding and deposit of the tax imposed under section #eija on a quarterly basis4 7#b7 ,records and information ,each taxpayer liable for tax under section #eija shall keep such records1 make such returns1 and furnish such information 7to the ,secretary and to other persons having an interest in the taxable crude oil or natural gas7 with respect to such oil as the ,secretary may by regulations prescribe4 7#c7 ,taxable periods2 return of tax 7,a7 ,taxable period ,except as provided by the ,secretary1 each calendar year shall constitute a taxable period4 7,b7 ,returns ,the ,secretary shall provide for the filing1 and the time for filing1 of the return of the tax imposed under section #eija4 7b7 ,definitions ,for purposes of this chapter-- 7#a7 ,producer ,the term producer means the holder of the economic interest with respect to the crude oil or natural gas4 7#b7 ,crude oil ,the term crude oil includes crude oil condensates and natural gasoline4 7#c7 ,premises and crude oil product ,the terms premises and crude oil product have the same meanings as when used for purposes of determining gross income from the property under section #fac4 7c7 ,adjustment of removal price ,in determining the removal price of oil or natural gas from a property in the case of any transaction1 the ,secretary may adjust the removal price to reflect clearly the fair market value of oil or natural gas removed4 7d7 ,regulations ,the ,secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this chapter4 4 7b7 ,deductibility of tax ,the first sentence of section #afd7;a7 of the ,internal ,revenue ,code of #aihf is amended by inserting after paragraph 7#d7 the following new paragraph3 7#e7 ,the tax imposed by section #eija7;a7 7after application of section #eija7;b77 on the severance of crude oil or natural gas from the outer ,continental ,shelf in the ,gulf of ,mexico4 4 7c7 ,clerical amendment ,the table of chapters for subtitle ,e is amended by adding at the end the following new item3 ,chapter #ef4 ,tax on severance of crude oil and natural gas from the outer ,continental ,shelf in the ,gulf of ,mexico4 4 7d7 ,effective date ,the amendments made by this section shall apply to crude oil or natural gas removed after ,december #ca1 #bjbe4 #bac4 ,repeal of corporate income tax exemption for publicly traded partnerships with qualifying income and gains from activities relating to fossil fuels 7a7 ,in general ,section #ggjd7;d77#a7 of the ,internal ,revenue ,code of #aihf is amended by inserting or any coal1 petroleum1 natural gas1 or any derivative of coal1 petroleum1 or natural gas that is used for fuel after section #fac7;b77#g74 7b7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after the date of the enactment of this ,act4 #bad4 ,amortization of qualified tertiary injectant expenses 7a7 ,in general ,section #aic of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking subsection 7a7 and inserting the following3 7a7 ,amortization of qualified tertiary injectant expenses 7#a7 ,in general ,any qualified tertiary injectant expenses paid or incurred by the taxpayer shall be allowed as a deduction ratably over the #hd-month period beginning on the date that such expense was paid or incurred4 7#b7 ,mid-month convention ,for purposes of paragraph 7#a71 any expenses paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month4 1 and 7#b7 by striking subsection 7c7 and inserting the following3 7c7 ,exclusive method ,except as provided in this section1 no depreciation or amortization deduction shall be allowed with respect to qualified tertiary injectant expenses4 4 7b7 ,effective date ,the amendments made by this section shall apply to expenses paid or incurred in taxable years beginning after the date of the enactment of this ,act4 #bae4 ,amortization of development expenditures 7a7 ,in general ,section #faf of the ,internal ,revenue ,code of #aihf is amended to read as follows3 #faf4 ,amortization of development expenditures 7a7 ,in general ,any expenditures paid or incurred for the development of a mine or other natural deposit 7other than an oil or gas well7 if paid or incurred after the existence of ores or minerals in commercially marketable quantities has been disclosed shall be allowed as a deduction ratably over the #hd-month period beginning on the date that such expenditure was paid or incurred4 7b7 ,mid-,month convention ,for purposes of subsection 7a71 any expenditures paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month4 7c7 ,exclusive method ,except as provided in this section1 no depreciation or amortization deduction shall be allowed with respect to expenditures described in subsection 7a74 7d7 ,treatment upon abandonment ,if any property with respect to which expenditures described in subsection 7a7 are paid or incurred is retired or abandoned during the #hd-month period described in such subsection1 no deduction shall be allowed on account of such retirement or abandonment and the amortization deduction under this section shall continue with respect to such payment4 4 7b7 ,conforming amendments 7#a7 ,the item relating to section #faf in the table of sections for part ,i of subchapter ,i of chapter #a of the ,internal ,revenue ,code of #aihf is amended to read as follows3 ,sec4 #faf4 ,amortization of development expenditures4 4 7#b7 ,section #ef7;a77#b77;,a7 of such ,code is amended by striking #faf7;a7 or4 7#c7 ,section #ei7;e7 of such ,code is amended-- 7,a7 in paragraph 7#b7-- 7i7 in subparagraph 7,c71 by inserting or at the end1 7ii7 by striking subparagraph 7,d71 and 7iii7 by redesignating subparagraph 7,e7 as subparagraph 7,d71 and 7,b7 in paragraph 7#e77;,a71 by striking 1 #faf7;a714 7#d7 ,section #bfc7;a77#a7 of such ,code is amended by striking subparagraph 7,a74 7#e7 ,section #bfc;,a7c77#c7 of such ,code is amended by striking #faf14 7#f7 ,section #bia7;b7 of such ,code is amended-- 7,a7 in paragraph 7#a77;,b71 by striking #faf7;a7 or1 7,b7 in paragraph 7#b71 by striking 1 #faf7;a711 and 7,c7 in paragraph 7#c71 by striking 1 #faf7;a714 7#g7 ,section #cab7n77#b77;,b7 of such ,code is amended by striking #faf7;a7 or4 7#h7 ,section #cha7;c7 of such ,code is amended by striking paragraph 7#aj74 7#i7 ,section #ajaf7;a7 of such ,code is amended by striking paragraph 7#i74 7#aj7 ,section #abed7;a77#a77;,a77i7 of such ,code is amended by striking 1 #faf14 7c7 ,effective date ,the amendments made by this section shall apply to expenditures paid or incurred in taxable years beginning after the date of the enactment of this ,act4 #baf4 ,amortization of certain mining exploration expenditures 7a7 ,in general ,section #fag of the ,internal ,revenue ,code of #aihf is amended to read as follows3 #fag4 ,amortization of certain mining exploration expenditures 7a7 ,in general ,any expenditures paid or incurred for the purpose of ascertaining the existence1 location1 extent1 or quality of any deposit of ore or other mineral1 and paid or incurred before the beginning of the development stage of the mine1 shall be allowed as a deduction ratably over the #hd-month period beginning on the date that such expense was paid or incurred4 7b7 ,mid-,month convention ,for purposes of subsection 7a71 any expenditures paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month4 7c7 ,exclusive method ,except as provided in this section1 no depreciation or amortization deduction shall be allowed with respect to expenditures described in subsection 7a74 7d7 ,treatment upon abandonment ,if any property with respect to which expenditures described in subsection 7a7 are paid or incurred is retired or abandoned during the #hd-month period described in such subsection1 no deduction shall be allowed on account of such retirement or abandonment and the amortization deduction under this section shall continue with respect to such payment4 4 7b7 ,conforming amendments 7#a7 ,the item relating to section #fag in the table of sections for part ,i of subchapter ,i of chapter #a of the ,internal ,revenue ,code of #aihf is amended to read as follows3 ,sec4 #fag4 ,amortization of certain mining exploration expenditures4 4 7#b7 ,section #ef7;a7 of such ,code1 as amended by section #bae7;b77#b71 is amended by striking paragraph 7#b74 7#c7 ,section #ei7;e7 of such ,code1 as amended by section #bae7;b77#c71 is amended-- 7,a7 in paragraph 7#b7-- 7i7 in subparagraph 7,b71 by inserting or at the end1 7ii7 in subparagraph 7,c71 by striking the comma at the end and inserting a period1 and 7iii7 by striking subparagraph 7,d71 and 7,b7 by striking paragraph 7#e7 and inserting the following3 7#e7 ,dispositions ,in the case of any disposition of property to which section #abed applies 7determined without regard to this section71 any deduction under paragraph 7#a7 with respect to amounts which are allocable to such property shall1 for purposes of section #abed1 be treated as a deduction allowable under section #bfc7;c74 4 7#d7 ,section #agj7;e7 of such ,code is amended-- 7,a7 in paragraph 7#a71 by striking #fag7;d77#a711 and 7,b7 in paragraph 7#c77;,d71 by striking #fag14 7#e7 ,section #bfc;,a7c77#c7 of such ,code1 as amended by section #bae7;b77#e71 is amended by striking #bia7;b77#b71 or #fag and inserting or #bia7;b77#b74 7#f7 ,section #bia7;b7 of such ,code1 as amended by section #bae7;b77#f71 is amended-- 7,a7 in the heading1 by striking and mineral exploration and development costs1 7,b7 by striking paragraph 7#a7 and inserting the following3 7#a7 ,in general ,in the case of an integrated oil company1 the amount allowable as a deduction for any taxable year 7determined without regard to this section7 under section #bfc7;c7 shall be reduced by #cj percent4 1 7,c7 in paragraph 7#b71 by striking or #fag7;a7 7as the case may be71 and 7,d7 in paragraph 7#c71 by striking or #fag7;a7 7whichever is appropriate74 7#g7 ,section #cab7n71 as amended by section #bae7;b77#g71 is amended by striking paragraph 7#b7 and inserting the following3 7#b7 ,intangible drilling costs ,any amount allowable as a deduction under section #bfc7;c7 in determining taxable income 7other than costs incurred in connection with a nonproductive well7-- 7,a7 shall be capitalized1 and 7,b7 shall be allowed as a deduction ratably over the #fj-month period beginning with the month in which such amount was paid or incurred4 4 7#h7 ,section #gjc7;b7 of such ,code is amended-- 7,a7 in paragraph 7#a71 by adding or at the end1 7,b7 by striking paragraph 7#b71 and 7,c7 by redesignating paragraph 7#c7 as paragraph 7#b74 7#i7 ,section #gea7;c7 of such ,code is amended-- 7,a7 by inserting 1 as in effect on the day before the date of the enactment of the ,end ,polluter ,welfare ,act of #bjbe after section #fag7;f77#b71 and 7,b7 by striking #fag7;d77#a714 7#aj7 ,section #abed7;a77#a77;,a77i7 of such ,code1 as amended by section #bae7;b77#aj71 is amended by striking or #fag4 7#aa7 ,paragraph 7#b7 of section #acfc7;c7 of such ,code is amended to read as follows3 7#b7 ,exception ,in the case of an ,s corporation1 elections under section #ija 7relating to taxes of foreign countries and possessions of the ,united ,states7 shall be made by each shareholder separately4 4 7c7 ,effective date ,the amendments made by this section shall apply to expenditures paid or incurred in taxable years beginning after the date of the enactment of this ,act4 #bag4 ,amortization of 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 to read as follows3 7c7 ,intangible drilling and development costs in the case of oil and gas wells and geothermal wells 7#a7 ,geothermal wells ,notwithstanding subsection 7a71 and except as provided in subsection 7i71 a taxpayer may elect to deduct as expenses intangible drilling and development costs in the case of wells drilled for any geothermal deposit 7as defined in section #fac7;e77#b77 in such manner as the ,secretary provides4 ,this subsection shall not apply with respect to any costs to which any deduction is allowed under section #ei7;e74 7#b7 ,oil and gas wells ,notwithstanding subsection 7a71 and except as provided in subsection 7i71 in the case of any expenses paid or incurred in taxable years beginning after the date of the enactment of ,end ,polluter ,welfare ,act of #bjbe in connection with intangible drilling and development costs related to oil and gas wells-- 7,a7 such expenses shall be allowed as a deduction ratably over the #hd-month period beginning on the date that such expense was paid or incurred1 7,b7 any such expenses paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month1 7,c7 except as provided in this paragraph1 no depreciation or amortization deduction shall be allowed with respect to such expenses1 and 7,d7 if any property with respect to which such intangible drilling and development costs are paid or incurred is retired or abandoned during such #hd-month period1 no deduction shall be allowed on account of such retirement or abandonment and the amortization deduction under this paragraph shall continue with respect to such payment4 4 7b7 ,conforming amendments 7#a7 ,paragraph 7#b7 of section #eg7;a7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7#b7 ,intangible drilling costs 7,a7 ,in general ,with respect to all geothermal properties of the taxpayer1 the amount 7if any7 by which the amount of the excess intangible drilling costs arising in the taxable year is greater than #fe percent of the net income of the taxpayer from geothermal properties for the taxable year4 7,b7 ,excess intangible drilling costs ,for purposes of subparagraph 7,a71 the amount of the excess intangible drilling costs arising in the taxable year is the excess of-- 7i7 the intangible drilling and development costs paid or incurred in connection with geothermal wells 7other than costs incurred in drilling a nonproductive well7 allowable under section #bfc7;c77#a7 for the taxable year1 over 7ii7 the amount which would have been allowable for the taxable year if such costs had been capitalized and straight line recovery of intangibles 7as defined in subsection 7b77 had been used with respect to such costs4 7,c7 ,net income from geothermal properties ,for purposes of subparagraph 7,a71 the amount of the net income of the taxpayer from geothermal properties for the taxable year is the excess of-- 7i7 the aggregate amount of gross income 7within the meaning of section #fac7;a77 from all geothermal properties of the taxpayer received or accrued by the taxpayer during the taxable year1 over 7ii7 the amount of any deductions allocable to such properties reduced by the excess described in subparagraph 7,b7 for such taxable year4 4 7#b7 ,section #ei7;e7 of such ,code1 as amended by sections #bae and #baf1 is amended-- 7,a7 in paragraph 7#b77;,c71 by striking section #bfc7;c7 and inserting section #bfc7;c77#a71 and 7,b7 in paragraph 7#e71 by striking section #bfc7;c7 and inserting section #bfc7;c77#a74 7#c7 ,section #bfc;,a7c77#c7 of such ,code1 as amended by sections #bae and #baf1 is amended-- 7,a7 in the heading1 by striking oil and gas and inserting geothermal1 and 7,b7 by striking #bfc7;c71 and inserting #bfc7;c77#a74 7#d7 ,section #bia of such ,code1 as amended by sections #bae and #baf1 is amended by striking subsection 7b74 7#e7 ,section #cab7n7 of such ,code1 as amended by sections #bae and #baf1 is amended by striking section #bfc7;c71 and inserting section #bfc7;c77#a74 7c7 ,effective date ,the amendments made by this section shall apply to expenditures paid or incurred in taxable years beginning after the date of the enactment of this ,act4 #bah4 ,increase in excise tax rate for funding of ,black ,lung ,disability ,trust ,fund 7a7 ,in general ,section #daba7;b7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 in paragraph 7#a71 by striking #a4aj and inserting #a4ch1 and 7#b7 in paragraph 7#b71 by striking 4#ee and inserting #j4fi4 7b7 ,effective date ,the amendments made by this section shall apply on and after the first day of the first calendar month beginning after the date of the enactment of this ,act4 #bai4 ,elimination of renewable electricity production credit eligibility for refined coal 7a7 ,in general ,section #de of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 in subsection 7b77#b7-- 7,a7 in the first sentence1 by striking 1 the #h cent amount and all that follows through in #bjjb and inserting and the #h cent amount in paragraph 7#a71 and 7,b7 in the third sentence1 by striking ,in any other case1 if an amount and inserting ,if the #h cent amount1 7#b7 in subsection 7c71 by striking paragraph 7#g71 7#c7 in subsection 7d71 by striking paragraph 7#h71 and 7#d7 in subsection 7e7-- 7,a7 by striking paragraph 7#h71 and 7,b7 by striking paragraph 7#i7 and inserting the following3 7#i7 ,coordination with credit for producing fuel from a nonconventional source ,the term qualified facility shall not include any facility which produces electricity from gas derived from the biodegradation of municipal solid waste if such biodegradation occurred in a facility 7within the meaning of section #de,k7 the production from which is allowed as a credit under section #de,k for the taxable year or any prior taxable year4 4 7b7 ,conforming amendments 7#a7 ,section #ch7;c77#d77;,b77iv7 of the ,internal ,revenue ,code of #aihf is amended by striking or refined coal4 7#b7 ,section #de,k7g77#b7 of such ,code is amended by striking subparagraph 7,e74 7c7 ,effective date ,the amendments made by this section shall apply to coal produced after ,december #ca1 #bjbe4 #bbj4 ,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 7f7 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 7f7 ,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 7as in effect on the day before the date of enactment of the ,end ,polluter ,welfare ,act of #bjbe7 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 subclauses 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 #bba4 ,repeal of exclusion of foreign oil and gas extraction income from the determination of tested income 7a7 ,in general ,section #iea;,a7c77#b77;,a77i7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by adding and at the end of subclause 7,,iii71 7#b7 by striking and at the end of subclause 7,,iv7 and inserting over1 and 7#c7 by striking subclause 7,v74 7b7 ,effective date ,the amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of enactment of this ,act1 and to taxable years of ,united ,states shareholders in which or with which such taxable years of foreign corporations end4 #bbb4 ,termination of credit for carbon oxide sequestration 7a7 ,in general ,section #de,q of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7j7 ,termination ,this section shall not apply with respect to any qualified carbon oxide captured after the date of enactment of the ,end ,polluter ,welfare ,act of #bjbe4 4 7b7 ,report 7#a7 ,in general ,not later than #f months after the date of enactment of this ,act1 the ,secretary of the ,treasury1 or the ,secretary's delegate1 shall submit a report to ,congress1 to be made available to the public1 which provides the following information3 7,a7 ,the taxpayer identity information of any taxpayer for which the carbon oxide sequestration credit under section #de,q of the ,internal ,revenue ,code of #aihf was allowed for any taxable year following the enactment of such section4 7,b7 ,the total amount of the credit allowed pursuant to such section to each taxpayer described in subparagraph 7,a74 7,c7 ,with respect to the amount described in subparagraph 7,b71 the amount of such credit allowed with respect to each of the following3 7i7 ,qualified carbon oxide which was captured and disposed of by the taxpayer in secure geological storage and not used by the taxpayer as described in clause 7ii7 or 7iii74 7ii7 ,qualified carbon oxide which was captured and used by the taxpayer as a tertiary injectant in a qualified enhanced oil or natural gas recovery project and disposed of by the taxpayer in secure geological storage4 7iii7 ,qualified carbon oxide which was captured and utilized by the taxpayer in a manner described in section #de,q7f77#e7 of the ,internal ,revenue ,code of #aihf4 7#b7 ,exception from rules regarding confidentiality and disclosure of returns and return information ,section #fajc7l7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following3 7#bc7 ,disclosure of return information for public report on carbon oxide sequestration credit ,the ,secretary may disclose taxpayer identity information and return information to the extent the ,secretary deems necessary for purposes of the report issued pursuant to section #bbb of the ,end ,polluter ,welfare ,act of #bjbe4 4 #bbc4 ,eliminate drawbacks on petroleum taxes 7a7 ,in general ,section #cac7;j7 of the ,tariff ,act of #aicj 7#ai ,u4,s4,c4 #acac7;j77 is amended by adding at the end the following new paragraph3 7#g7 ,no amount of any tax imposed on any merchandise pursuant to section #dfaa of the ,internal ,revenue ,code of #aihf shall be eligible to be refunded as drawback under this subsection4 4 7b7 ,effective date ,the amendment made by this section shall apply with respect to articles entered1 or withdrawn from warehouse for consumption1 on or after ,january #a1 #bjbf4 #bbd4 ,modifying clean hydrogen production credit 7a7 ,in general ,section #de,v of the ,internal ,revenue ,code of #aihf1 as amended by section #gjeaa of ,public ,law #aai-ba1 is amended-- 7#a7 in subsection 7a71 by striking paragraph 7#b7 and inserting the following3 7#b7 #j4fj4 1 7#b7 by striking subsection 7b7 and inserting the following3 7b7 ,inflation adjustment ,the #j4fj amount in subsection 7a77#b7 shall be adjusted by multiplying such amount by the inflation adjustment factor 7as determined under section #de7;e77#b71 determined by substituting #bjbd for #aiib in subparagraph 7,b7 thereof7 for the calendar year in which the qualified clean hydrogen is produced4 ,if any amount as increased under the preceding sentence is not a multiple of #j4a cent1 such amount shall be rounded to the nearest multiple of #j4a cent4 1 7#c7 in subsection 7c7-- 7,a7 by striking paragraph 7#a71 7,b7 in paragraph 7#b7-- 7i7 by striking subparagraph 7,a7 and inserting the following3 7,a7 ,definition 7i7 ,in general ,the term qualified clean hydrogen means hydrogen produced using an electrolyzer for which the electricity used is-- 7,i7 produced at a facility which-- 7aa7 uses qualified renewable energy resources to produce such electricity1 7bb7 was placed in service not greater than #cf months prior to the date on which the facility which produces such hydrogen was placed in service1 and 7cc7 is in the same region 7as defined in the ,national ,transmission ,needs ,study of the ,department of ,energy1 dated ,october #cj1 #bjbc7 as the facility which produces such hydrogen1 and 7,,ii7 produced at the facility described in subclause 7,i7 not less than #a hour prior to use by the electrolyzer4 7ii7 ,qualified renewable energy resources ,the term qualified renewable energy resources means-- 7,i7 wind1 7,,ii7 solar energy1 7,,iii7 geothermal energy 7as defined in section #de7;c77#d771 7,,iv7 marine and hydrokinetic renewable energy 7as defined in section #de7;c77#aj771 and 7,v7 hydropower4 1 and 7ii7 by striking subparagraph 7,c71 7,c7 in paragraph 7#c77;,c71 by inserting 1 and which is placed in service after ,december #ca1 #bjbe after ,january #a1 #bjbh1 and 7,d7 by redesignating paragraphs 7#b7 and 7#c7 as paragraphs 7#a7 and 7#b71 respectively1 7#d7 in subsection 7e7-- 7,a7 in paragraph 7#a71 by striking described in subsection 7b77#b7 and inserting produced by the taxpayer1 and 7,b7 in paragraph 7#c77;,a77ii71 by striking subsection 7a77#b7 and inserting subsection 7a77#a71 and 7#e7 in subsection 7f71 by striking 1 including regulations or other guidance for determining lifecycle greenhouse gas emissions4 7b7 ,conforming amendments 7#a7 ,section #de7;e77#ac7 of the ,internal ,revenue ,code of #aihf is amended by striking section #de,v7c77#c77 to produce qualified clean hydrogen 7as defined in section #de,v7c77#b77 and inserting section #de,v7c77#b77 to produce qualified clean hydrogen 7as defined in section #de,v7c77#a774 7#b7 ,section #dh7;a77#ae7 of such ,code is amended-- 7,a7 in subparagraph 7,a71 by striking clause 7ii7 and inserting the following3 7ii7 the energy percentage with respect to such property is #f percent4 1 7,b7 in subparagraph 7,c7-- 7i7 by striking section #de,v7c77#c7 and inserting section #de,v7c77#b71 and 7ii7 in clause 7i71 by striking ,december #ca1 #bjbb and inserting ,december #ca1 #bjbe1 and 7,c7 in subparagraph 7,d71 by striking section #de,v7c77#b7 and inserting section #de,v7c77#a74 7#c7 ,section #fdag of such ,code is amended-- 7,a7 in subsection 7b77#e71 by striking ,december #ca1 #bjab and inserting ,december #ca1 #bjbe1 and 7,b7 in subsection 7d77#a77;,b71 by striking section #de,v7c77#c7 and inserting section #de,v7c77#b74 7c7 ,effective date ,the amendments made by this section shall apply to facilities placed in service after ,december #ca1 #bjbe4 ,,iii ,repeal recent fossil fuel subsidy legislation #cja4 ,,builder ,act 7a7 ,general repeal ,sections #ajf1 #ajg1 #ajh1 #aji1 #aaj1 and #aaa of the ,national ,environmental ,policy ,act of #aifi 7#db ,u4,s4,c4 #dccf1 #dccf;a1 #dccf;b1 #dccf;c1 #dccf;d1 #dccf;e7 are repealed4 7b7 ,repeal of modifications ,section #ajb7b7 of the ,national ,environmental ,policy ,act of #aifi 7#db ,u4,s4,c4 #dccb7b77 is amended-- 7#a7 in subparagraph 7,c7-- 7,a7 in the matter preceding clause 7i71 by striking consistent with the provisions of this ,act and except where compliance would be inconsistent with other statutory requirements12 7,b7 by striking clauses 7i7 through 7v7 and inserting the following3 7i7 the environmental impact of the proposed action2 7ii7 any adverse environmental effects that cannot be avoided if the proposed action is implemented2 7iii7 alternatives to the proposed action2 7iv7 the relationship between local short-term uses of the human environment and the maintenance and enhancement of long-term productivity2 and 7v7 any irreversible and irretrievable commitments of resources that would be involved in the proposed action if the proposed action is implemented4 2 and 7,c7 in the undesignated matter following clause 7v7 7as so amended71 in the first sentence1 by striking head of the lead agency and inserting responsible ,federal official2 7#b7 by striking subparagraphs 7,d71 7,e71 and 7,f72 7#c7 by redesignating subparagraphs 7,g7 through 7,l7 as subparagraphs 7,d7 through 7,i71 respectively2 and 7#d7 in subparagraph 7,f7 7as so redesignated71 by striking consistent with the provisions of this ,act14 7c7 ,conforming amendment ,section #iiji7;c77#a7 of the ,william ,m4 7,mac7 ,thornberry ,national ,defense ,authorization ,act for ,fiscal ,year #bjba 7#ae ,u4,s4,c4 #dfei7;c77#a77 is amended by striking has the meaning given the term in section #aaa of ,,nepa 7#db ,u4,s4,c4 #dccf;e7 and inserting 1 with respect to a covered activity1 means the ,federal agency that proposed the covered activity4 #cjb4 ,inflation ,reduction ,act 7a7 ,lease sales under the #bjag-bjbb outer ,continental ,shelf leasing program ,section #ejbfd of ,public ,law #aag-afi 7commonly known as the ,inflation ,reduction ,act of #bjbb7 7#acf ,stat4 #bjei7 is repealed4 7b7 ,ensuring energy security ,section #ejbfe of ,public ,law #aag-afi 7commonly known as the ,inflation ,reduction ,act of #bjbb7 7#dc ,u4,s4,c4 #cjjf7 is repealed4 #cjc4 ,one ,big ,beautiful ,bill ,act 7a7 ,internal ,revenue ,code 7#a7 ,exclusion of metallurgical coal under advanced manufacturing production credit ,section #de,x of the ,internal ,revenue ,code of #aihf1 as amended by section #gjead of ,public ,law #aai-ba 7commonly known as the ,one ,big ,beautiful ,bill ,act71 is amended-- 7,a7 in subsection 7b77#a77,m71 by striking 7#b4e percent in the case of metallurgical coal71 7,b7 in subsection 7b77#c7-- 7i7 in subparagraph 7,c7-- 7,i7 in the heading1 by striking other than metallurgical coal1 7,,ii7 in clause 7i71 by striking 7other than metallurgical coal71 and 7,,iii7 in the heading of clause 7ii71 by striking other than metallurgical coal1 and 7ii7 by striking subparagraph 7,e71 and 7,c7 in subsection 7c77#f71 by striking subparagraph 7,r74 7#b7 ,intangible drilling and development costs ,the amendments made by section #gjebc of ,public ,law #aai-ba are repealed and the ,internal ,revenue ,code of #aihf shall be applied as if such amendments had not been enacted4 7#c7 ,income from carbon capture and hydrogen ,section #ggjd7;d77#a77;,e7 of the ,internal ,revenue ,code of #aihf1 as amended by section #gjebd of ,public ,law #aai-ba1 is amended-- 7,a7 in clause 7ii77,,ii71 by inserting provided that such hydrogen is qualified clean hydrogen 7as defined in section #de,v7c77#a77;,a771 after liquified hydrogen or compressed hydrogen11 and 7,b7 by striking clause 7iii74 7b7 ,oil and gas1 mining1 and energy repeals ,the provisions of1 and the amendments made by1 sections #ejaja1 #ejajb1 #ejajc1 #ejajd1 #ejaje1 #ejbja1 #ejbjb1 #ejbjc1 #ejbjd1 and #ejdjc of ,public ,law #aai-ba 7commonly known as the ,one ,big ,beautiful ,bill ,act7 7#aci ,stat4 #gb7 are repealed1 and any provision of law amended or repealed by those sections shall be applied as if such amendments or repeals had not been enacted4 7c7 ,methane emissions and waste reduction incentive program ,section #acf7;g7 of the ,clean ,air ,act 7#db ,u4,s4,c4 #gdcf7;g77 7as amended by section #fjjab7;b7 of ,public ,law #aai-ba 7commonly known as the ,one ,big ,beautiful ,bill ,act77 7#aci ,stat4 #gb7 is amended by striking calendar year #bjcd and inserting calendar year #bjbd4 7d7 ,repeal of project sponsor opt-,in fees for environmental reviews ,section #aab of the ,national ,environmental ,policy ,act of #aifi 7as added by section #fjjbf of ,public ,law #aai-ba 7commonly known as the ,one ,big ,beautiful ,bill ,act77 7#aci ,stat4 #gb7 is repealed4 #cjd4 ,waste emissions charge rule 7a7 ,repeal ,public ,law #aai-b 7#aci ,stat4 #g7 is repealed4 7b7 ,implementation ,the ,administrator of the ,environmental ,protection ,agency shall implement the final rule of the ,environmental ,protection ,agency entitled ,waste ,emissions ,charge for ,petroleum and ,natural ,gas ,systems3 ,procedures for ,facilitating ,compliance1 ,including ,netting and ,exemptions 7#hi ,fed4 ,reg4 #iajid 7,november #ah1 #bjbd77 as if ,public ,law #aai-b 7#aci ,stat4 #g7 had not been enacted into law4 ,,iv ,elimination of other fossil fuel subsidies #dja4 ,study and elimination of additional fossil fuel subsidies 7a7 ,definition of subsidy for fossil-,fuel production ,in this section1 the term subsidy for fossil-fuel production means any direct funding1 tax treatment or incentive1 risk-reduction benefit1 financing assistance or guarantee1 royalty relief1 or other provision that provides a financial benefit to a fossil-fuel company for the production of fossil fuels4 7b7 ,report to ,congress ,not later than #a year after the date of enactment of this ,act1 the ,secretary of the ,treasury or a delegate of the ,secretary 7referred to in this section as the ,secretary71 in coordination with the ,secretary of ,energy1 shall submit to ,congress a report detailing each ,federal law 7including regulations71 other than those amended by this ,act1 as in effect on the date on which the report is submitted1 that includes a subsidy for fossil-fuel production4 7c7 ,report on modified recovery period 7#a7 ,in general ,not later than #a year after the date of enactment of this ,act1 the ,secretary1 in coordination with the ,commissioner of ,internal ,revenue1 shall submit to ,congress a report on the applicable recovery period under the accelerated cost recovery system provided in section #afh of the ,internal ,revenue ,code of #aihf for each type of property involved in fossil-fuel production1 including pipelines1 power generation property1 refineries1 and drilling equipment1 to determine if any assets are receiving a subsidy for fossil-fuel production4 7#b7 ,elimination of subsidy 7,a7 ,in general ,in the case of any type of property that the ,secretary determines is receiving a subsidy for fossil-fuel production under section #afh of the ,internal ,revenue ,code of #aihf1 for property placed in service in taxable years beginning after the date of such determination1 section #afh of the ,internal ,revenue ,code of #aihf shall not apply4 7,b7 ,exception ,subparagraph 7,a7 shall not apply to any property with respect to a taxable year unless such determination is published before the first day of such taxable year4