MURPFL 024 XML
MURPFL 024 XML
MURPFL 024 XML
XML
H. R. ll
To eliminate unnecessary oil tax credits and subsidies for major oil companies to reduce the national debt.
A BILL
To eliminate unnecessary oil tax credits and subsidies for major oil companies to reduce the national debt. 1 Be it enacted by the Senate and House of Representa-
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2 1 2 3 4 5 6 7 8 9
TITLE IREPEAL OF OIL AND GAS SUBSIDIES Subtitle AClose Big Oil Tax Loopholes
SEC. 101. MODIFICATIONS OF FOREIGN TAX CREDIT RULES APPLICABLE TO MAJOR INTEGRATED OIL COMPANIES TAXPAYERS. WHICH ARE DUAL CAPACITY
10 enue Code of 1986 is amended by redesignating subsection 11 (n) as subsection (o) and by inserting after subsection (m) 12 the following new subsection: 13 14 (n) SPECIAL RULES RELATING
GRATED TO
MAJOR INTE-
15 TAXPAYERS. 16 17 18 19 20 21 22 23 24 25
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(1) GENERAL
RULE.Notwithstanding
any
other provision of this chapter, any amount paid or accrued by a dual capacity taxpayer which is a major integrated oil company (as defined in section 167(h)(5)(B)) to a foreign country or possession of the United States for any period shall not be considered a tax (A) if, for such period, the foreign country or possession does not impose a generally applicable income tax, or
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3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (B) to the extent such amount exceeds the amount (determined in accordance with regulations) which (i) is paid by such dual capacity taxpayer pursuant to the generally applicable income tax imposed by the country or possession, or (ii) would be paid if the generally applicable income tax imposed by the country or possession were applicable to such dual capacity taxpayer. 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 (B). (2) DUAL
CAPACITY TAXPAYER.For
pur-
poses of this subsection, the term dual capacity taxpayer means, with respect to any foreign country or possession of the United States, a person who (A) is subject to a levy of such country or possession, and (B) receives (or will receive) directly or indirectly a specific economic benefit (as determined in accordance with regulations) from such country or possession.
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4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 (3) GENERALLY
APPLICABLE INCOME TAX.
term generally
applicable income tax means an income tax (or a series of income taxes) 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 possession. (B) EXCEPTIONS.Such term shall not include a tax unless it has substantial application, by its terms and in practice, to (i) persons who are not dual capacity taxpayers, and (ii) persons who are citizens or residents of the foreign country or possession.. (b) EFFECTIVE DATE. (1) 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 Act. (2) CONTRARY
TREATY OBLIGATIONS
UPHELD.The
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5 1 2 3 4 5 6 shall not apply to the extent contrary to any treaty obligation of the United States.
SEC. 102. LIMITATION ON SECTION 199 DEDUCTION ATTRIBUTABLE TO OIL, NATURAL GAS, OR PRIMARY PRODUCTS THEREOF.
(a) DENIAL
OF
7 tion 199(c) of the Internal Revenue Code of 1986 is 8 amended by adding at the end the following new subpara9 graph: 10 11 12 13 14 15 16 17 18 19 (E) SPECIAL
RULE FOR CERTAIN OIL
who is a major integrated oil company (as defined in section 167(h)(5)(B)) for the taxable year, the term domestic production gross receipts shall not include gross receipts from the production, transportation, or distribution of oil, natural gas, or any primary product (within the meaning of subsection (d)(9)) thereof.. (b) EFFECTIVE DATE.The amendment made by
20 this section shall apply to taxable years beginning after 21 December 31, 2013. 22 23 24
SEC. 103. LIMITATION ON DEDUCTION FOR INTANGIBLE DRILLING AND DEVELOPMENT COSTS.
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6 1 the following new sentence: This subsection shall not 2 apply to amounts paid or incurred by a taxpayer in any 3 taxable year in which such taxpayer is a major integrated 4 oil company (as defined in section 167(h)(5)(B)).. 5 (b) EFFECTIVE DATE.The amendment made by
6 this section shall apply to amounts paid or incurred in tax7 able years beginning after December 31, 2013. 8 9 10
SEC. 104. LIMITATION ON PERCENTAGE DEPLETION ALLOWANCE FOR OIL AND GAS WELLS.
11 enue Code of 1986 is amended by adding at the end the 12 following new subsection: 13 14 (f) APPLICATION WITH RESPECT
GRATED TO
MAJOR INTE-
15 in which the taxpayer is a major integrated oil company 16 (as defined in section 167(h)(5)(B)), the allowance for 17 percentage depletion shall be zero.. 18 (b) EFFECTIVE DATE.The amendment made by
19 this section shall apply to taxable years beginning after 20 December 31, 2013. 21 22 23
SEC. 105. LIMITATION ON DEDUCTION FOR TERTIARY INJECTANTS.
24 enue Code of 1986 is amended by adding at the end the 25 following new subsection:
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MAJOR INTE-
3 amounts paid or incurred by a taxpayer in any taxable 4 year in which such taxpayer is a major integrated oil com5 pany (as defined in section 167(h)(5)(B)).. 6 (b) EFFECTIVE DATE.The amendment made by
7 this section shall apply to amounts paid or incurred in tax8 able years beginning after December 31, 2013. 9 10 11 12 13
14 ergy Policy Act of 2005 (42 U.S.C. 15904, 15905) are 15 repealed. 16 (b) LIMITATION ON APPLICATION.The repeal under
17 subsection (a) shall not affect the application of the re18 pealed sections with respect to any lease sale for which 19 a notice of sale is published before the date of enactment 20 of this Act. 21 22 23
24 of the enactment of this Act and the amendments made 25 by this Act (after any expenditures authorized by this Act
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8 1 and the amendments made by this Act) shall be deposited 2 in the Treasury and used for Federal budget deficit reduc3 tion or, if there is no Federal budget deficit, for reducing 4 the Federal debt in such manner as the Secretary of the 5 Treasury considers appropriate.
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