I 

118TH CONGRESS 

2D SESSION H. R. 8554 

To eliminate certain subsidies for fossil-fuel production. 

IN THE HOUSE OF REPRESENTATIVES 

MAY 23, 2024 

Ms. OMAR (for herself, Ms. BARRAGA ́N, Mr. BOWMAN, Ms. BUSH, Mr. CARSON, Mr. CLEAVER, Mr. COHEN, Mr. ESPAILLAT, Mr. FROST, Mr. ROBERT GARCIA of California, Mr. GRIJALVA, Mr. JACKSON of Illinois, Ms. 

JAYAPAL, Ms. KAMLAGER-DOVE, Mr. KHANNA, Ms. LEE of California, 

Ms. MCCOLLUM, Ms. NORTON, Ms. PINGREE, Ms. PRESSLEY, Mrs. RAMIREZ, Mr. RASKIN, Ms. SCHAKOWSKY, Mr. SCHIFF, Mr. TAKANO, Ms. 

TLAIB, Mr. TORRES of New York, and Mrs. WATSON COLEMAN) introduced the following bill; which was referred to the Committee on Ways 

and Means, and in addition to the Committees on Natural Resources, 

Transportation and Infrastructure, Financial Services, Science, Space, 

and Technology, Agriculture, Energy and Commerce, Foreign Affairs, 

and Appropriations, for a period to be subsequently determined by the 

Speaker, in each case for consideration of such provisions as fall within 

the jurisdiction of the committee concerned 

A BILL 

To eliminate certain subsidies for fossil-fuel production. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘End Polluter Welfare 

5 Act of 2024’’. 


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1 SEC. 2. TABLE OF CONTENTS. 

2 The table of contents for this Act is as follows: 

Sec. 1. Short title. 

Sec. 2. Table of contents. 

TITLE I—ELIMINATION OF FOSSIL FUEL SUBSIDIES 

Sec. 101. Definition of fossil fuel. 

Sec. 102. Royalty relief. 

Sec. 103. Royalties under Mineral Leasing Act. 

Sec. 104. Offshore oil and gas royalty rate. 

Sec. 105. Elimination of interest payments for royalty overpayments. 

Sec. 106. Removal of limits on liability for offshore facilities and pipeline operators. 

Sec. 107. Restrictions on use of appropriated funds by international financial 

institutions for projects that support fossil fuel. 

Sec. 108. Office of Fossil Energy and Carbon Management. 

Sec. 109. Loan Programs Office of the Department of Energy. 

Sec. 110. USDA assistance for carbon capture and storage systems. 

Sec. 111. Advanced Research Projects Agency—Energy. 

Sec. 112. Incentives for innovative technologies. 

Sec. 113. Rural Utility Service loan guarantees. 

Sec. 114. Prohibition on use of funds by the United States International Development Finance Corporation or the Export-Import Bank of the 

United States for financing projects, transactions, or other activities that support fossil fuel. 

Sec. 115. Transportation funds for grants, loans, loan guarantees, and other direct assistance. 

Sec. 116. Elimination of exclusion of certain lenders as owners or operators 

under CERCLA. 

Sec. 117. Powder River Basin. 

TITLE II—AMENDMENTS TO INTERNAL REVENUE CODE OF 1986 

Sec. 201. Termination of various tax expenditures relating to fossil fuels. 

Sec. 202. Termination of certain deductions and credits related to fossil fuels. 

Sec. 203. Uniform seven-year amortization for geological and geophysical expenditures. 

Sec. 204. Natural gas gathering lines treated as 15-year property. 

Sec. 205. Termination of last-in, first-out method of inventory for oil, natural 

gas, and coal companies. 

Sec. 206. Repeal of percentage depletion for coal and hard mineral fossil fuels. 

Sec. 207. Termination of capital gains treatment for royalties from coal. 

Sec. 208. Modifications of foreign tax credit rules applicable to oil and gas industry taxpayers receiving specific economic benefits. 

Sec. 209. Increase in oil spill liability trust fund financing rate. 

Sec. 210. Application of certain environmental taxes to synthetic crude oil. 

Sec. 211. Denial of deduction for removal costs and damages for certain oil 

spills. 

Sec. 212. Tax on crude oil and natural gas produced from the outer Continental Shelf in the Gulf of Mexico. 

Sec. 213. Repeal of corporate income tax exemption for publicly traded partnerships with qualifying income and gains from activities relating 

to fossil fuels. 


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Sec. 214. Amortization of qualified tertiary injectant expenses. 

Sec. 215. Amortization of development expenditures. 

Sec. 216. Amortization of certain mining exploration expenditures. 

Sec. 217. Amortization of intangible drilling and development costs in the case 

of oil and gas wells. 

Sec. 218. Increase in excise tax rate for funding of Black Lung Disability Trust 

Fund. 

Sec. 219. Elimination of renewable electricity production credit eligibility for refined coal. 

Sec. 220. Treatment of foreign oil related income as subpart F income. 

Sec. 221. Repeal of exclusion of foreign oil and gas extraction income from the 

determination of tested income. 

Sec. 222. Termination of credit for carbon oxide sequestration. 

Sec. 223. Eliminate drawbacks on petroleum taxes. 

Sec. 224. Modifying clean hydrogen production credit. 

TITLE III—REPEAL RECENT FOSSIL FUEL SUBSIDY LEGISLATION 

Sec. 301. Fiscal Responsibility Act. 

Sec. 302. Inflation Reduction Act. 

TITLE IV—ELIMINATION OF OTHER FOSSIL FUEL SUBSIDIES 

Sec. 401. Study and elimination of additional fossil fuel subsidies. 

1 TITLE I—ELIMINATION OF 

2 FOSSIL FUEL SUBSIDIES 

3 SEC. 101. DEFINITION OF FOSSIL FUEL. 

4 In this Act, the term ‘‘fossil fuel’’ means coal, petro5 leum, natural gas, or any derivative of coal, petroleum, 

6 or natural gas that is used for fuel. 

7 SEC. 102. ROYALTY RELIEF. 

8 (a) IN GENERAL.— 

9 (1) OUTER CONTINENTAL SHELF LANDS ACT.— 

10 Section 8(a)(3) of the Outer Continental Shelf 

11 Lands Act (43 U.S.C. 1337(a)(3)) is amended— 

12 (A) by striking subparagraph (B); and 

13 (B) by redesignating subparagraph (C) as 

14 subparagraph (B). 


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1 (2) ENERGY POLICY ACT OF 2005.— 

2 (A) INCENTIVES FOR NATURAL GAS PRO3 DUCTION FROM DEEP WELLS IN THE SHALLOW

4 WATERS OF THE GULF OF MEXICO.—Section 

5 344 of the Energy Policy Act of 2005 (42 

6 U.S.C. 15904) is repealed. 

7 (B) DEEP WATER PRODUCTION.—Section 

8 345 of the Energy Policy Act of 2005 (42 

9 U.S.C. 15905) is repealed. 

10 (3) CLERICAL AMENDMENT.—The table of con11 tents in section 1(b) of the Energy Policy Act of 

12 2005 (Public Law 109–58; 119 Stat. 596) is amend13 ed by striking the items relating to sections 344 and 

14 345. 

15 (b) FUTURE PROVISIONS.—Notwithstanding any 

16 other provision of law, royalty relief shall not be permitted 

17 under a lease issued under section 8 of the Outer Conti18 nental Shelf Lands Act (43 U.S.C. 1337). 

19 SEC. 103. ROYALTIES UNDER MINERAL LEASING ACT. 

20 (a) COAL LEASES.—Section 7(a) of the Mineral 

21 Leasing Act (30 U.S.C. 207(a)) is amended in the fourth 

sentence by striking ‘‘121 22 ⁄2 per centum’’ and inserting 

‘‘183 23 ⁄4 percent’’. 

24 (b) LEASES ON LAND ON WHICH OIL OR NATURAL

25 GAS IS DISCOVERED.—Section 14 of the Mineral Leasing 


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1 Act (30 U.S.C. 223) is amended in the fourth sentence 

by striking ‘‘121⁄2 per centum’’ and inserting ‘‘183 2 ⁄4 per3 cent’’. 

4 (c) LEASES ON LAND KNOWN OR BELIEVED TO

5 CONTAIN OIL OR NATURAL GAS.—Section 17 of the Min6 eral Leasing Act (30 U.S.C. 226) is amended— 

7 (1) in subsection (b)— 

8 (A) in paragraph (1)(A), in the fifth sentence, by striking ‘‘162 9 ⁄3 percent’’ each place it 

appears and inserting ‘‘183 10 ⁄4 percent’’; and 

11 (B) in paragraph (2)(A)(ii), by striking 

‘‘162 12 ⁄3 per centum’’ and inserting ‘‘not less than 

183 13 ⁄4 percent’’; 

(2) in subsection (l), by striking ‘‘162 14 ⁄3 per centum’’ each place it appears and inserting ‘‘183 15 ⁄4 per16 cent’’; and 

(3) in subsection (n)(1)(C), by striking ‘‘162 17 ⁄3

per centum’’ and inserting ‘‘not less than 183 18 ⁄4 per19 cent’’. 

20 SEC. 104. OFFSHORE OIL AND GAS ROYALTY RATE. 

21 Section 8(a)(1) of the Outer Continental Shelf Lands 

22 Act (43 U.S.C. 1337(a)(1)) is amended by striking ‘‘but 

not more than 183 23 ⁄4 percent, during the 10-year period 

24 beginning on the date of enactment of the Act titled ‘An 

25 Act to provide for reconciliation pursuant to title II of S. 


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Con. Res. 14’, and not less than 162 1 ⁄3 percent thereafter,’’ 

2 each place it appears. 

3 SEC. 105. ELIMINATION OF INTEREST PAYMENTS FOR ROY4 ALTY OVERPAYMENTS. 

5 Section 111 of the Federal Oil and Gas Royalty Man6 agement Act of 1982 (30 U.S.C. 1721) is amended by 

7 adding at the end the following: 

8 ‘‘(k) PAYMENT OF INTEREST.—Interest shall not be 

9 paid on any overpayment.’’. 

10 SEC. 106. REMOVAL OF LIMITS ON LIABILITY FOR OFF11 SHORE FACILITIES AND PIPELINE OPERA12 TORS. 

13 Section 1004(a) of the Oil Pollution Act of 1990 (33 

14 U.S.C. 2704(a)) is amended— 

15 (1) in paragraph (3), by striking ‘‘plus 

16 $75,000,000; and’’ and inserting ‘‘and the liability 

17 of the responsible party under section 1002;’’; 

18 (2) in paragraph (4)— 

19 (A) by inserting ‘‘(except an onshore pipe20 line transporting diluted bitumen, bituminous 

21 mixtures, or any oil manufactured from bitu22 men)’’ after ‘‘for any onshore facility’’; and 

23 (B) by striking the period at the end and 

24 inserting ‘‘; and’’; and 

25 (3) by adding at the end the following: 


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1 ‘‘(5) for any onshore facility transporting di2 luted bitumen, bituminous mixtures, or any oil man3 ufactured from bitumen, the liability of the respon4 sible party under section 1002.’’. 

5 SEC. 107. RESTRICTIONS ON USE OF APPROPRIATED 

6 FUNDS BY INTERNATIONAL FINANCIAL INSTI7 TUTIONS FOR PROJECTS THAT SUPPORT 

8 FOSSIL FUEL. 

9 (a) DEFINITION OF INTERNATIONAL FINANCIAL IN10 STITUTION.—In this section, the term ‘‘international fi11 nancial institution’’ means— 

12 (1) each institution described in section 

13 1701(c)(2) of the International Financial Institu14 tions Act (22 U.S.C. 262r(c)(2)); and 

15 (2) the North American Development Bank. 

16 (b) RESCISSION OF UNOBLIGATED FUNDS.— 

17 (1) IN GENERAL.—Of the unobligated balance 

18 of amounts appropriated or otherwise made available 

19 for a contribution of the United States to an inter20 national financial institution, an amount specified in 

21 paragraph (2) shall be rescinded if the institution 

22 provides support for a project that supports the pro23 duction or use of fossil fuels. 

24 (2) AMOUNT SPECIFIED.—The amount specified 

25 in this paragraph is an amount the Secretary of the 


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1 Treasury determines to be equivalent to the amount 

2 of support provided by an international financial in3 stitution described in paragraph (1) for a project 

4 that supports the production or use of fossil fuels. 

5 (c) PROHIBITION ON USE OF FUTURE FUNDS.—No 

6 amounts appropriated or otherwise made available for a 

7 contribution of the United States to an international fi8 nancial institution may be provided to the institution un9 less the institution agrees to not use the amount to provide 

10 support for any project that supports the production or 

11 use of fossil fuels. 

12 SEC. 108. OFFICE OF FOSSIL ENERGY AND CARBON MAN13 AGEMENT. 

14 (a) TERMINATION OF AUTHORITY.—Notwithstanding 

15 any other provision of law, the authority of the Secretary 

16 of Energy to carry out the Office of Fossil Energy and 

17 Carbon Management of the Department of Energy is ter18 minated. 

19 (b) RESCISSION.—Notwithstanding any other provi20 sion of law— 

21 (1) all amounts made available for the Office of 

22 Fossil Energy and Carbon Management that remain 

23 unobligated as of the date of enactment of this Act 

24 are rescinded; and 


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1 (2) no amounts made available after the date of 

2 enactment of this Act for the Office of Fossil En3 ergy and Carbon Management shall be expended, 

4 other than such amounts as are necessary to cover 

5 costs incurred in terminating ongoing research of 

6 the Office of Fossil Energy and Carbon Manage7 ment, as determined by the Secretary of Energy, in 

8 consultation with other appropriate Federal agen9 cies. 

10 SEC. 109. LOAN PROGRAMS OFFICE OF THE DEPARTMENT 

11 OF ENERGY . 

12 (a) PROHIBITION.—Subject to subsection (b), none of 

13 the funds made available to the Loan Programs Office of 

14 the Department of Energy shall be used to carry out any 

15 project that supports fossil fuel, carbon capture, or hydro16 gen. 

17 (b) EXCEPTION.—The prohibition on the use of funds 

18 for hydrogen projects under subsection (a) does not apply 

19 to projects that support qualified clean hydrogen (as de20 fined in section 45V(c) of the Internal Revenue Code of 

21 1986 (as amended by section 224(a)(3))). 


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1 SEC. 110. USDA ASSISTANCE FOR CARBON CAPTURE AND 

2 STORAGE SYSTEMS. 

3 Section 9003(j)(1) of the Farm Security and Rural 

4 Investment Act of 2002 (7 U.S.C. 8103(j)(1)) is amend5 ed— 

6 (1) by inserting ‘‘and’’ after ‘‘renewable energy 

7 systems,’’; and 

8 (2) by striking ‘‘and carbon capture and stor9 age systems,’’. 

10 SEC. 111. ADVANCED RESEARCH PROJECTS AGENCY—EN11 ERGY. 

12 None of the funds made available to the Advanced 

13 Research Projects Agency—Energy shall be used to carry 

14 out any project that supports fossil fuel. 

15 SEC. 112. INCENTIVES FOR INNOVATIVE TECHNOLOGIES. 

16 (a) IN GENERAL.—Section 1703 of the Energy Policy 

17 Act of 2005 (42 U.S.C. 16513) is amended— 

18 (1) in subsection (b)— 

19 (A) by striking paragraphs (2) and (10); 

20 and 

21 (B) by redesignating paragraphs (3), (4), 

22 (5), (6), (7), (8), (9), (11), (12), and (13) as 

23 paragraphs (2), (3), (4), (5), (6), (7), (8), (9), 

24 (10), and (11) respectively; 

25 (2) by striking subsection (c); and 


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1 (3) by redesignating subsections (d) through (f) 

2 as subsections (c) through (e), respectively. 

3 (b) CONFORMING AMENDMENT.—Section 1704 of the 

4 Energy Policy Act of 2005 (42 U.S.C. 16514) is amend5 ed— 

6 (1) by striking subsection (b); and 

7 (2) by redesignating subsection (c) as sub8 section (b). 

9 SEC. 113. RURAL UTILITY SERVICE LOAN GUARANTEES. 

10 Notwithstanding any other provision of law, the Sec11 retary of Agriculture may not make a loan under title III 

12 of the Rural Electrification Act of 1936 (7 U.S.C. 931 

13 et seq.) to an applicant for the purpose of carrying out 

14 any project that will use fossil fuel. 

15 SEC. 114. PROHIBITION ON USE OF FUNDS BY THE UNITED 

16 STATES INTERNATIONAL DEVELOPMENT FI17 NANCE CORPORATION OR THE EXPORT-IM18 PORT BANK OF THE UNITED STATES FOR FI19 NANCING PROJECTS, TRANSACTIONS, OR 

20 OTHER ACTIVITIES THAT SUPPORT FOSSIL 

21 FUEL. 

22 Notwithstanding any other provision of law, no 

23 amounts appropriated or otherwise made available for the 

24 United States International Development Finance Cor25 poration, the Export-Import Bank of the United States, 


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1 the United States Trade and Development Agency, the 

2 United States Agency for International Development, or 

3 the Millennium Challenge Corporation that are available 

4 for obligation on or after the date of enactment of this 

5 Act may be obligated or expended to support any project, 

6 transaction, or other activity that supports the production 

7 or use of fossil fuels. 

8 SEC. 115. TRANSPORTATION FUNDS FOR GRANTS, LOANS, 

9 LOAN GUARANTEES, AND OTHER DIRECT AS10 SISTANCE. 

11 Notwithstanding any other provision of law, any 

12 amounts made available to the Department of Transpor13 tation (including the Federal Railroad Administration) 

14 may not be used to award any grant, loan, loan guarantee, 

15 or provide any other direct assistance to any rail facility 

16 or port project that transports fossil fuel. 

17 SEC. 116. ELIMINATION OF EXCLUSION OF CERTAIN LEND18 ERS AS OWNERS OR OPERATORS UNDER 

19 CERCLA. 

20 Section 101(20)(F) of the Comprehensive Environ21 mental Response, Compensation, and Liability Act of 

22 1980 (42 U.S.C. 9601(20)(F)) is amended by adding at 

23 the end the following: 


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1 ‘‘(iii) INELIGIBLE LENDERS.—The ex2 clusions under clauses (i) and (ii) shall not 

3 apply to a person that is a lender that is— 

4 ‘‘(I) an investment company reg5 istered under the Investment Com6 pany Act of 1940 (15 U.S.C. 80a–1 et 

7 seq.), an investment adviser (as de8 fined in section 202(a) of the Invest9 ment Advisers Act of 1940 (15 U.S.C. 

10 80b–2(a))), or a broker or dealer (as 

11 those terms are defined in section 

12 3(a) of the Securities Exchange Act of 

13 1934 (15 U.S.C. 78c(a))) with 

14 $250,000,000,000 or more in assets 

15 under management; or 

16 ‘‘(II) a bank holding company (as 

17 defined in section 2 of the Bank Hold18 ing Company Act of 1956 (12 U.S.C. 

19 1841)) with $10,000,000,000 or more 

20 in total consolidated assets.’’. 

21 SEC. 117. POWDER RIVER BASIN. 

22 (a) DESIGNATION OF THE POWDER RIVER BASIN AS

23 A COAL PRODUCING REGION.—As soon as practicable 

24 after the date of enactment of this Act, the Director of 


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1 the Bureau of Land Management shall designate the Pow2 der River Basin as a coal producing region. 

3 (b) REPORT.—Not later than 1 year after the date 

4 of enactment of this Act, the Director of the Bureau of 

5 Land Management shall submit to Congress a report that 

6 includes— 

7 (1) a study of the fair market value and the 

8 amount and effective rate of royalties paid on coal 

9 leases in the Powder River Basin compared to other 

10 national and international coal basins and markets; 

11 and 

12 (2) any policy recommendations to capture the 

13 future market value of the coal leases in the Powder 

14 River Basin. 

15 TITLE II—AMENDMENTS TO IN16 TERNAL REVENUE CODE OF 

17 1986 

18 SEC. 201. TERMINATION OF VARIOUS TAX EXPENDITURES 

19 RELATING TO FOSSIL FUELS. 

20 (a) IN GENERAL.—Subchapter C of chapter 80 of the 

21 Internal Revenue Code of 1986 is amended by adding at 

22 the end the following new section: 


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1 ‘‘SEC. 7875. TERMINATION OF CERTAIN PROVISIONS RELAT2 ING TO FOSSIL-FUEL INCENTIVES. 

3 ‘‘(a) IN GENERAL.—The following provisions shall 

4 not apply to taxable years beginning after the date of the 

5 enactment of the End Polluter Welfare Act of 2024: 

6 ‘‘(1) Section 43 (relating to enhanced oil recov7 ery credit). 

8 ‘‘(2) Section 45I (relating to credit for pro9 ducing oil and natural gas from marginal wells). 

10 ‘‘(3) Section 461(i)(2) (relating to special rule 

11 for spudding of oil or natural gas wells). 

12 ‘‘(4) Section 469(c)(3)(A) (relating to working 

13 interests in oil and natural gas property). 

14 ‘‘(5) Section 613A (relating to limitations on 

15 percentage depletion in case of oil and natural gas 

16 wells). 

17 ‘‘(b) PROVISIONS RELATING TO PROPERTY.—The 

18 following provisions shall not apply to property placed in 

19 service after the date of the enactment of the End Polluter 

20 Welfare Act of 2024: 

21 ‘‘(1) Section 168(e)(3)(C)(iii) (relating to clas22 sification of certain property). 

23 ‘‘(2) Section 169 (relating to amortization of 

24 pollution control facilities) with respect to any at25 mospheric pollution control facility. 


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1 ‘‘(c) PROVISIONS RELATING TO COSTS AND EX2 PENSES.—The following provisions shall not apply to costs 

3 or expenses paid or incurred after the date of the enact4 ment of the End Polluter Welfare Act of 2024: 

5 ‘‘(1) Section 179B (relating to deduction for 

6 capital costs incurred in complying with Environ7 mental Protection Agency sulfur regulations). 

8 ‘‘(2) Section 468 (relating to special rules for 

9 mining and solid waste reclamation and closing 

10 costs). 

11 ‘‘(d) ALLOCATED CREDITS.—No new credits shall be 

12 certified under section 48A (relating to qualifying ad13 vanced coal project credit) after the date of the enactment 

14 of the End Polluter Welfare Act of 2024. 

15 ‘‘(e) ARBITRAGE BONDS.—Section 148(b)(4) (relat16 ing to safe harbor for prepaid natural gas) shall not apply 

17 to obligations issued after the date of the enactment of 

18 the End Polluter Welfare Act of 2024.’’. 

19 (b) CONFORMING AMENDMENTS.— 

20 (1) Section 613(d) of the Internal Revenue 

21 Code of 1986 is amended by striking ‘‘Except as 

22 provided in section 613A, in the case’’ and inserting 

23 ‘‘In the case’’. 


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1 (2) The table of sections for subchapter C of 

2 chapter 90 of such Code is amended by adding at 

3 the end the following new item: 

‘‘Sec. 7875. Termination of certain provisions relating to fossil-fuel incentives.’’. 

4 SEC. 202. TERMINATION OF CERTAIN DEDUCTIONS AND 

5 CREDITS RELATED TO FOSSIL FUELS. 

6 (a) SPECIAL ALLOWANCE FOR CERTAIN PROP7 ERTY.—Section 168(k) of the Internal Revenue Code of 

8 1986 is amended by adding at the end the following: 

9 ‘‘(11) FOSSIL FUEL PROPERTY.— 

10 ‘‘(A) IN GENERAL.—This subsection shall 

11 not apply with respect to any property which is 

12 primarily used for fossil fuel activities and is 

13 placed in service during any taxable year begin14 ning after the date of the enactment of the End 

15 Polluter Welfare Act of 2024. 

16 ‘‘(B) FOSSIL FUEL ACTIVITIES.—For pur17 poses of this paragraph, the term ‘fossil fuel ac18 tivities’ means the exploration, development, 

19 mining or production, processing, refining, 

20 transportation (including pipelines transporting 

21 gas, oil, or products thereof), distribution, or 

22 marketing of coal, petroleum, natural gas, or 

23 any derivative of coal, petroleum, or natural gas 

24 that is used for fuel. 


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1 ‘‘(C) EXCEPTION.—The property described 

2 in subparagraph (A) shall not include any 

3 motor vehicle service station or convenience 

4 store which does not qualify as a retail motor 

5 fuels outlet under subsection (e)(3)(E)(iii).’’. 

6 (b) QUALIFIED BUSINESS INCOME.—Section 

7 199A(c)(3)(B) of the Internal Revenue Code of 1986 is 

8 amended by adding at the end the following: 

9 ‘‘(viii) Any item of gain or loss de10 rived from fossil fuel activities (as defined 

11 in section 168(k)(11)(B)) during any tax12 able year beginning after the date of the 

13 enactment of the End Polluter Welfare Act 

14 of 2024.’’. 

15 (c) CREDIT FOR INCREASING RESEARCH ACTIVI16 TIES.—Section 41(d)(4) of the Internal Revenue Code of 

17 1986 is amended by adding at the end the following: 

18 ‘‘(I) FOSSIL FUEL ACTIVITIES.—Any re19 search related to fossil fuel activities (as defined 

20 in section 168(k)(11)(B)) which is conducted 

21 after the date of the enactment of the End Pol22 luter Welfare Act of 2024.’’. 

23 (d) FOREIGN-DERIVED INTANGIBLE INCOME.—Sub24 clause (V) of section 250(b)(3)(A)(i) of the Internal Rev25 enue Code of 1986 is amended to read as follows: 


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1 ‘‘(V) any income derived from 

2 fossil fuel activities (as defined in sec3 tion 168(k)(11)(B)) during any tax4 able year beginning after the date of 

5 the enactment of the End Polluter 

6 Welfare Act of 2024, and’’. 

7 (e) EXCHANGE OF REAL PROPERTY HELD FOR PRO8 DUCTIVE USE OR INVESTMENT.—Section 1031(a)(2) of 

9 the Internal Revenue Code of 1986 is amended to read 

10 as follows: 

11 ‘‘(2) EXCEPTIONS.—This subsection shall not 

12 apply to— 

13 ‘‘(A) any exchange of real property held 

14 primarily for sale, or 

15 ‘‘(B) any exchange of real property 

16 which— 

17 ‘‘(i) is used for fossil fuel activities (as 

18 defined in section 168(k)(11)(B)), and 

19 ‘‘(ii) occurs after the date of the en20 actment of the End Polluter Welfare Act 

21 of 2024.’’. 

22 SEC. 203. UNIFORM SEVEN-YEAR AMORTIZATION FOR GEO23 LOGICAL AND GEOPHYSICAL EXPENDITURES. 

24 (a) IN GENERAL.—Section 167(h) of the Internal 

25 Revenue Code of 1986 is amended— 


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1 (1) by striking ‘‘24-month period’’ each place it 

2 appears in paragraphs (1) and (4) and inserting 

3 ‘‘84-month period’’, 

4 (2) by striking paragraph (2) and inserting the 

5 following: 

6 ‘‘(2) MID-MONTH CONVENTION.—For purposes 

7 of paragraph (1), any payment paid or incurred dur8 ing any month shall be treated as paid or incurred 

9 on the mid-point of such month.’’, and 

10 (3) by striking paragraph (5). 

11 (b) EFFECTIVE DATE.—The amendments made by 

12 this section shall apply to amounts paid or incurred after 

13 the date of the enactment of this Act. 

14 SEC. 204. NATURAL GAS GATHERING LINES TREATED AS 15- 

15 YEAR PROPERTY. 

16 (a) IN GENERAL.—Section 168(e)(3)(E) of the Inter17 nal Revenue Code of 1986 is amended by striking ‘‘and’’ 

18 at the end of clause (vi), by striking the period at the end 

19 of clause (vii) and inserting ‘‘, and’’, and by adding at 

20 the end the following new clause: 

21 ‘‘(viii) any natural gas gathering line 

22 the original use of which commences with 

23 the taxpayer after the date of the enact24 ment of this clause.’’. 


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1 (b) ALTERNATIVE SYSTEM.—The table contained in 

2 section 168(g)(3)(B) of the Internal Revenue Code of 

3 1986 is amended by inserting after the item relating to 

4 subparagraph (E)(vii) the following new item: 

‘‘(E)(viii) ................................................................................................. 22’’. 

5 (c) CONFORMING AMENDMENT.—Clause (iv) of sec6 tion 168(e)(3)(C) of the Internal Revenue Code of 1986 

7 is amended by inserting ‘‘and on or before the date of the 

8 enactment of the End Polluter Welfare Act of 2024’’ after 

9 ‘‘April 11, 2005’’. 

10 (d) EFFECTIVE DATE.— 

11 (1) IN GENERAL.—The amendments made by 

12 this section shall apply to property placed in service 

13 on and after the date of the enactment of this Act. 

14 (2) EXCEPTION.—The amendments made by 

15 this section shall not apply to any property with re16 spect to which the taxpayer or a related party has 

17 entered into a binding contract for the construction 

18 thereof on or before the date of the introduction of 

19 this Act, or, in the case of self-constructed property, 

20 has started construction on or before such date. 


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1 SEC. 205. TERMINATION OF LAST-IN, FIRST-OUT METHOD 

2 OF INVENTORY FOR OIL, NATURAL GAS, AND 

3 COAL COMPANIES. 

4 (a) IN GENERAL.—Section 472 of the Internal Rev5 enue Code of 1986 is amended by adding at the end the 

6 following new subsection: 

7 ‘‘(h) TERMINATION FOR OIL, NATURAL GAS, AND

8 COAL COMPANIES.—Subsection (a) shall not apply to any 

9 taxpayer that is in the trade or business of the production, 

10 refining, processing, transportation, or distribution of oil, 

11 natural gas, or coal for any taxable year beginning after 

12 the date of enactment of the End Polluter Welfare Act 

13 of 2024.’’. 

14 (b) ADDITIONAL TERMINATION.—Section 473 of the 

15 Internal Revenue Code of 1986 is amended by adding at 

16 the end the following new subsection: 

17 ‘‘(h) TERMINATION FOR OIL, NATURAL GAS, AND

18 COAL COMPANIES.—This section shall not apply to any 

19 taxpayer that is in the trade or business of the production, 

20 refining, processing, transportation, or distribution of oil, 

21 natural gas, or coal for any taxable year beginning after 

22 the date of enactment of the End Polluter Welfare Act 

23 of 2024.’’. 

24 (c) CHANGE IN METHOD OF ACCOUNTING.—In the 

25 case of any taxpayer required by the amendments made 

26 by this section to change its method of accounting for its 


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1 first taxable year beginning after the date of enactment 

2 of this Act— 

3 (1) such change shall be treated as initiated by 

4 the taxpayer, and 

5 (2) such change shall be treated as made with 

6 the consent of the Secretary of the Treasury. 

7 (d) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to taxable years beginning after 

9 the date of enactment of this Act. 

10 SEC. 206. REPEAL OF PERCENTAGE DEPLETION FOR COAL 

11 AND HARD MINERAL FOSSIL FUELS. 

12 (a) IN GENERAL.—Section 613 of the Internal Rev13 enue Code of 1986 is amended by adding at the end the 

14 following new subsection: 

15 ‘‘(f) TERMINATION WITH RESPECT TO COAL AND

16 HARD MINERAL FOSSIL FUELS.—In the case of coal, lig17 nite, and oil shale (other than oil shale described in sub18 section (b)(5)), the allowance for depletion shall be com19 puted without reference to this section for any taxable 

20 year beginning after the date of the enactment of the End 

21 Polluter Welfare Act of 2024.’’. 

22 (b) CONFORMING AMENDMENTS.— 

23 (1) COAL AND LIGNITE.—Section 613(b)(4) of 

24 the Internal Revenue Code of 1986 is amended by 

25 striking ‘‘coal, lignite,’’. 


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1 (2) OIL SHALE.—Section 613(b)(2) of such 

2 Code is amended to read as follows: 

3 ‘‘(2) 15 PERCENT.—If, from deposits in the 

4 United States, gold, silver, copper, and iron ore.’’. 

5 (c) EFFECTIVE DATE.—The amendments made by 

6 this section shall apply to taxable years beginning after 

7 the date of the enactment of this Act. 

8 SEC. 207. TERMINATION OF CAPITAL GAINS TREATMENT 

9 FOR ROYALTIES FROM COAL. 

10 (a) IN GENERAL.—Subsection (c) of section 631 of 

11 the Internal Revenue Code of 1986 is amended— 

12 (1) by striking ‘‘coal (including lignite), or iron 

13 ore’’ and inserting ‘‘iron ore’’, 

14 (2) by striking ‘‘coal or iron ore’’ each place it 

15 appears and inserting ‘‘iron ore’’, 

16 (3) by striking ‘‘iron ore or coal’’ each place it 

17 appears and inserting ‘‘iron ore’’, and 

18 (4) by striking ‘‘COAL OR’’ in the heading. 

19 (b) CONFORMING AMENDMENTS.— 

20 (1) The heading of section 631 of the Internal 

21 Revenue Code of 1986 is amended by striking ‘‘, 

22 COAL,’’. 

23 (2) Section 1231(b)(2) of such Code is amend24 ed by striking ‘‘, coal,’’. 


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1 (c) EFFECTIVE DATE.—The amendments made by 

2 this section shall apply to dispositions after the date of 

3 the enactment of this Act. 

4 SEC. 208. MODIFICATIONS OF FOREIGN TAX CREDIT RULES 

5 APPLICABLE TO OIL AND GAS INDUSTRY TAX6 PAYERS RECEIVING SPECIFIC ECONOMIC 

7 BENEFITS. 

8 (a) IN GENERAL.—Section 901 of the Internal Rev9 enue Code of 1986 is amended by redesignating subsection 

10 (n) as subsection (o) and by inserting after subsection (m) 

11 the following new subsection: 

12 ‘‘(n) SPECIAL RULES RELATING TO DUAL CAPACITY

13 TAXPAYERS.— 

14 ‘‘(1) GENERAL RULE.—Notwithstanding any 

15 other provision of this chapter, any amount paid or 

16 accrued to a foreign country or possession of the 

17 United States for any period by a dual capacity tax18 payer which is in the trade or business of the pro19 duction, refining, processing, transportation, or dis20 tribution of fossil fuel shall not be considered a 

21 tax— 

22 ‘‘(A) if, for such period, the foreign coun23 try or possession does not impose a generally 

24 applicable income tax, or 


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1 ‘‘(B) to the extent such amount exceeds 

2 the amount (determined in accordance with reg3 ulations) which— 

4 ‘‘(i) is paid by such dual capacity tax5 payer pursuant to the generally applicable 

6 income tax imposed by the country or pos7 session, or 

8 ‘‘(ii) would be paid if no amount other 

9 than the amount required to be paid by 

10 such taxpayer under the generally applica11 ble income tax imposed by the country or 

12 possession were paid or accrued by such 

13 dual capacity taxpayer. 

14 Nothing in this paragraph shall be construed to 

15 imply the proper treatment of any such amount 

16 not in excess of the amount determined under 

17 subparagraph (B). 

18 ‘‘(2) DUAL CAPACITY TAXPAYER.—For pur19 poses of this subsection, the term ‘dual capacity tax20 payer’ means, with respect to any foreign country or 

21 possession of the United States, a person who— 

22 ‘‘(A) is subject to a levy of such country or 

23 possession, and 

24 ‘‘(B) receives (or will receive) directly or 

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1 mined in accordance with regulations) from 

2 such country or possession. 

3 ‘‘(3) GENERALLY APPLICABLE INCOME TAX.— 

4 For purposes of this subsection— 

5 ‘‘(A) IN GENERAL.—The term ‘generally 

6 applicable income tax’ means an income tax (or 

7 a series of income taxes) which is generally im8 posed under the laws of a foreign country or 

9 possession on income derived from the conduct 

10 of a trade or business within such country or 

11 possession. 

12 ‘‘(B) EXCEPTIONS.—Such term shall not 

13 include a tax unless it has substantial applica14 tion, by its terms and in practice, to— 

15 ‘‘(i) persons who are not dual capacity 

16 taxpayers, and 

17 ‘‘(ii) persons who are— 

18 ‘‘(I) citizens or residents of the 

19 foreign country or possession, or 

20 ‘‘(II) organized or incorporated 

21 under the laws of the foreign country 

22 or possession. 

23 ‘‘(4) FOSSIL FUEL.—For purposes of this sub24 section, the term ‘fossil fuel’ means coal, petroleum, 


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1 natural gas, or any derivative of coal, petroleum, or 

2 natural gas that is used for fuel.’’. 

3 (b) EFFECTIVE DATE.—The amendments made by 

4 this section shall apply to taxes paid or accrued in taxable 

5 years beginning after the date of the enactment of this 

6 Act. 

7 (c) SPECIAL RULE FOR TREATIES.—Notwith8 standing sections 894 or 7852(d) of the Internal Revenue 

9 Code of 1986, the amendments made by this section shall 

10 apply without regard to any treaty obligation of the 

11 United States. 

12 SEC. 209. INCREASE IN OIL SPILL LIABILITY TRUST FUND 

13 FINANCING RATE. 

14 (a) IN GENERAL.—Section 4611 of the Internal Rev15 enue Code of 1986 is amended— 

16 (1) in subsection (c)(2)(B)— 

17 (A) in clause (i), by striking ‘‘and’’ at the 

18 end, 

19 (B) in clause (ii), by striking the period at 

20 the end and inserting ‘‘, and’’, and 

21 (C) by adding at the end the following: 

22 ‘‘(iii) in the case of crude oil received 

23 or petroleum products entered after De24 cember 31, 2024, 10 cents a barrel.’’, and 


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1 (2) by striking subsection (f) and inserting the 

2 following: 

3 ‘‘(f) APPLICATION OF OIL SPILL LIABILITY TRUST

4 FUND FINANCING RATE.—The Oil Spill Liability Trust 

5 Fund financing rate under subsection (c) shall apply on 

6 and after April 1, 2006, or if later, the date which is 30 

7 days after the last day of any calendar quarter for which 

8 the Secretary estimates that, as of the close of that quar9 ter, the unobligated balance in the Oil Spill Liability Trust 

10 Fund is less than $2,000,000,000.’’. 

11 (b) EFFECTIVE DATE.—The amendments made by 

12 this section shall apply to crude oil received and petroleum 

13 products entered after December 31, 2024. 

14 SEC. 210. APPLICATION OF CERTAIN ENVIRONMENTAL 

15 TAXES TO SYNTHETIC CRUDE OIL. 

16 (a) IN GENERAL.—Paragraph (1) of section 4612(a) 

17 of the Internal Revenue Code of 1986 is amended to read 

18 as follows: 

19 ‘‘(1) CRUDE OIL.— 

20 ‘‘(A) IN GENERAL.—The term ‘crude oil’ 

21 includes crude oil condensates, natural gasoline, 

22 and synthetic crude oil. 

23 ‘‘(B) SYNTHETIC CRUDE OIL.—For pur24 poses of subparagraph (A), the term ‘synthetic 

25 crude oil’ means— 


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1 ‘‘(i) any bitumen and bituminous mix2 tures, 

3 ‘‘(ii) any oil derived from bitumen and 

4 bituminous mixtures (including oil derived 

5 from tar sands), 

6 ‘‘(iii) any liquid fuel derived from 

7 coal, and 

8 ‘‘(iv) any oil derived from kerogen9 bearing sources (including oil derived from 

10 oil shale).’’. 

11 (b) REGULATORY AUTHORITY TO ADDRESS OTHER

12 TYPES OF CRUDE OIL AND PETROLEUM PRODUCTS.— 

13 Subsection (a) of section 4612 of the Internal Revenue 

14 Code of 1986 is amended by adding at the end the fol15 lowing: 

16 ‘‘(10) REGULATORY AUTHORITY TO ADDRESS

17 OTHER TYPES OF CRUDE OIL AND PETROLEUM

18 PRODUCTS.—Under such regulations as the Sec19 retary may prescribe, the Secretary may include as 

20 crude oil or as a petroleum product subject to tax 

21 under section 4611, any fuel feedstock or finished 

22 fuel product customarily transported by pipeline, 

23 vessel, railcar, or tanker truck if the Secretary deter24 mines that— 


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1 ‘‘(A) the classification of such fuel feed2 stock or finished fuel product is consistent with 

3 the definition of oil under the Oil Pollution Act 

4 of 1990, and 

5 ‘‘(B) such fuel feedstock or finished fuel 

6 product is produced in sufficient commercial 

7 quantities as to pose a significant risk of haz8 ard in the event of a discharge.’’. 

9 (c) TECHNICAL AMENDMENT.—Paragraph (2) of sec10 tion 4612(a) of the Internal Revenue Code of 1986 is 

11 amended by striking ‘‘from a well located’’. 

12 (d) EFFECTIVE DATE.—The amendments made by 

13 this section shall apply to oil and petroleum products re14 ceived or entered during calendar quarters beginning more 

15 than 60 days after the date of the enactment of this Act. 

16 SEC. 211. DENIAL OF DEDUCTION FOR REMOVAL COSTS 

17 AND DAMAGES FOR CERTAIN OIL SPILLS. 

18 (a) IN GENERAL.—Section 162(f) of the Internal 

19 Revenue Code of 1986 is amended— 

20 (1) by redesignating paragraph (5) as para21 graph (6), and 

22 (2) by inserting after paragraph (4) the fol23 lowing: 

24 ‘‘(5) EXPENSES FOR REMOVAL COSTS AND

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1 ITY.—Notwithstanding paragraphs (2) and (3), no 

2 deduction shall be allowed under this chapter for any 

3 costs or damages for which the taxpayer is liable 

4 under section 1002 of the Oil Pollution Act of 1990 

5 (33 U.S.C. 2702)’’. 

6 (b) EFFECTIVE DATE.—The amendments made by 

7 this section shall apply with respect to any liability arising 

8 in taxable years ending after the date of the enactment 

9 of this Act. 

10 SEC. 212. TAX ON CRUDE OIL AND NATURAL GAS PRO11 DUCED FROM THE OUTER CONTINENTAL 

12 SHELF IN THE GULF OF MEXICO. 

13 (a) IN GENERAL.—Subtitle E of the Internal Rev14 enue Code of 1986 is amended by adding at the end the 

15 following new chapter: 

16 ‘‘CHAPTER 56—TAX ON SEVERANCE OF 

17 CRUDE OIL AND NATURAL GAS FROM 

18 THE OUTER CONTINENTAL SHELF IN 

19 THE GULF OF MEXICO 

‘‘Sec. 5901. Imposition of tax. 

‘‘Sec. 5902. Taxable crude oil or natural gas and removal price. 

‘‘Sec. 5903. Special rules and definitions. 

20 ‘‘SEC. 5901. IMPOSITION OF TAX. 

21 ‘‘(a) IN GENERAL.—In addition to any other tax im22 posed under this title, there is hereby imposed a tax equal 

23 to 13 percent of the removal price of any taxable crude 


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1 oil or natural gas removed from the premises during any 

2 taxable period. 

3 ‘‘(b) CREDIT FOR FEDERAL ROYALTIES PAID.— 

4 ‘‘(1) IN GENERAL.—There shall be allowed as a 

5 credit against the tax imposed by subsection (a) with 

6 respect to the production of any taxable crude oil or 

7 natural gas an amount equal to the aggregate 

8 amount of royalties paid under Federal law with re9 spect to such production. 

10 ‘‘(2) LIMITATION.—The aggregate amount of 

11 credits allowed under paragraph (1) to any taxpayer 

12 for any taxable period shall not exceed the amount 

13 of tax imposed by subsection (a) for such taxable pe14 riod. 

15 ‘‘(c) TAX PAID BY PRODUCER.—The tax imposed by 

16 this section shall be paid by the producer of the taxable 

17 crude oil or natural gas. 

18 ‘‘SEC. 5902. TAXABLE CRUDE OIL OR NATURAL GAS AND RE19 MOVAL PRICE. 

20 ‘‘(a) TAXABLE CRUDE OIL OR NATURAL GAS.—For 

21 purposes of this chapter, the term ‘taxable crude oil or 

22 natural gas’ means crude oil or natural gas which is pro23 duced from Federal submerged lands on the outer Conti24 nental Shelf in the Gulf of Mexico pursuant to a lease 


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1 entered into with the United States which authorizes the 

2 production. 

3 ‘‘(b) REMOVAL PRICE.—For purposes of this chap4 ter— 

5 ‘‘(1) IN GENERAL.—Except as otherwise pro6 vided in this subsection, the term ‘removal price’ 

7 means— 

8 ‘‘(A) in the case of taxable crude oil, the 

9 amount for which a barrel of such crude oil is 

10 sold, and 

11 ‘‘(B) in the case of taxable natural gas, the 

12 amount per 1,000 cubic feet for which such 

13 natural gas is sold. 

14 ‘‘(2) SALES BETWEEN RELATED PERSONS.—In 

15 the case of a sale between related persons, the re16 moval price shall not be less than the constructive 

17 sales price for purposes of determining gross income 

18 from the property under section 613. 

19 ‘‘(3) OIL OR NATURAL GAS REMOVED FROM

20 PROPERTY BEFORE SALE.—If crude oil or natural 

21 gas is removed from the property before it is sold, 

22 the removal price shall be the constructive sales 

23 price for purposes of determining gross income from 

24 the property under section 613. 


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1 ‘‘(4) REFINING BEGUN ON PROPERTY.—If the 

2 manufacture or conversion of crude oil into refined 

3 products begins before such oil is removed from the 

4 property— 

5 ‘‘(A) such oil shall be treated as removed 

6 on the day such manufacture or conversion be7 gins, and 

8 ‘‘(B) the removal price shall be the con9 structive sales price for purposes of determining 

10 gross income from the property under section 

11 613. 

12 ‘‘(5) PROPERTY.—The term ‘property’ has the 

13 meaning given such term by section 614. 

14 ‘‘SEC. 5903. SPECIAL RULES AND DEFINITIONS. 

15 ‘‘(a) ADMINISTRATIVE REQUIREMENTS.— 

16 ‘‘(1) WITHHOLDING AND DEPOSIT OF TAX.— 

17 The Secretary shall provide for the withholding and 

18 deposit of the tax imposed under section 5901 on a 

19 quarterly basis. 

20 ‘‘(2) RECORDS AND INFORMATION.—Each tax21 payer liable for tax under section 5901 shall keep 

22 such records, make such returns, and furnish such 

23 information (to the Secretary and to other persons 

24 having an interest in the taxable crude oil or natural 


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1 gas) with respect to such oil as the Secretary may 

2 by regulations prescribe. 

3 ‘‘(3) TAXABLE PERIODS; RETURN OF TAX.— 

4 ‘‘(A) TAXABLE PERIOD.—Except as pro5 vided by the Secretary, each calendar year shall 

6 constitute a taxable period. 

7 ‘‘(B) RETURNS.—The Secretary shall pro8 vide for the filing, and the time for filing, of the 

9 return of the tax imposed under section 5901. 

10 ‘‘(b) DEFINITIONS.—For purposes of this chapter— 

11 ‘‘(1) PRODUCER.—The term ‘producer’ means 

12 the holder of the economic interest with respect to 

13 the crude oil or natural gas. 

14 ‘‘(2) CRUDE OIL.—The term ‘crude oil’ includes 

15 crude oil condensates and natural gasoline. 

16 ‘‘(3) PREMISES AND CRUDE OIL PRODUCT.— 

17 The terms ‘premises’ and ‘crude oil product’ have 

18 the same meanings as when used for purposes of de19 termining gross income from the property under sec20 tion 613. 

21 ‘‘(c) ADJUSTMENT OF REMOVAL PRICE.—In deter22 mining the removal price of oil or natural gas from a prop23 erty in the case of any transaction, the Secretary may ad24 just the removal price to reflect clearly the fair market 

25 value of oil or natural gas removed. 


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1 ‘‘(d) REGULATIONS.—The Secretary shall prescribe 

2 such regulations as may be necessary or appropriate to 

3 carry out the purposes of this chapter.’’. 

4 (b) DEDUCTIBILITY OF TAX.—The first sentence of 

5 section 164(a) of the Internal Revenue Code of 1986 is 

6 amended by inserting after paragraph (4) the following 

7 new paragraph: 

8 ‘‘(5) The tax imposed by section 5901(a) (after 

9 application of section 5901(b)) on the severance of 

10 crude oil or natural gas from the outer Continental 

11 Shelf in the Gulf of Mexico.’’. 

12 (c) CLERICAL AMENDMENT.—The table of chapters 

13 for subtitle E is amended by adding at the end the fol14 lowing new item: 

‘‘CHAPTER 56. Tax on severance of crude oil and natural gas 

from the outer Continental Shelf in the Gulf of 

Mexico.’’. 

15 (d) EFFECTIVE DATE.—The amendments made by 

16 this section shall apply to crude oil or natural gas removed 

17 after December 31, 2024. 

18 SEC. 213. REPEAL OF CORPORATE INCOME TAX EXEMP19 TION FOR PUBLICLY TRADED PARTNERSHIPS 

20 WITH QUALIFYING INCOME AND GAINS FROM 

21 ACTIVITIES RELATING TO FOSSIL FUELS. 

22 (a) IN GENERAL.—Section 7704(d)(1) of the Inter23 nal Revenue Code of 1986 is amended by inserting ‘‘or 

24 any coal, petroleum, natural gas, or any derivative of coal, 


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1 petroleum, or natural gas that is used for fuel’’ after ‘‘sec2 tion 613(b)(7)’’. 

3 (b) EFFECTIVE DATE.—The amendment made by 

4 this section shall apply to taxable years beginning after 

5 the date of the enactment of this Act. 

6 SEC. 214. AMORTIZATION OF QUALIFIED TERTIARY 

7 INJECTANT EXPENSES. 

8 (a) IN GENERAL.—Section 193 of the Internal Rev9 enue Code of 1986 is amended— 

10 (1) by striking subsection (a) and inserting the 

11 following: 

12 ‘‘(a) AMORTIZATION OF QUALIFIED TERTIARY

13 INJECTANT EXPENSES.— 

14 ‘‘(1) IN GENERAL.—Any qualified tertiary 

15 injectant expenses paid or incurred by the taxpayer 

16 shall be allowed as a deduction ratably over the 84- 

17 month period beginning on the date that such ex18 pense was paid or incurred. 

19 ‘‘(2) MID-MONTH CONVENTION.—For purposes 

20 of paragraph (1), any expenses paid or incurred dur21 ing any month shall be treated as paid or incurred 

22 on the mid-point of such month.’’, and 

23 (2) by striking subsection (c) and inserting the 

24 following: 


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1 ‘‘(c) EXCLUSIVE METHOD.—Except as provided in 

2 this section, no depreciation or amortization deduction 

3 shall be allowed with respect to qualified tertiary injectant 

4 expenses.’’. 

5 (b) EFFECTIVE DATE.—The amendments made by 

6 this section shall apply to expenses paid or incurred in 

7 taxable years beginning after the date of the enactment 

8 of this Act. 

9 SEC. 215. AMORTIZATION OF DEVELOPMENT EXPENDI10 TURES. 

11 (a) IN GENERAL.—Section 616 of the Internal Rev12 enue Code of 1986 is amended to read as follows: 

13 ‘‘SEC. 616. AMORTIZATION OF DEVELOPMENT EXPENDI14 TURES. 

15 ‘‘(a) IN GENERAL.—Any expenditures paid or in16 curred for the development of a mine or other natural de17 posit (other than an oil or gas well) if paid or incurred 

18 after the existence of ores or minerals in commercially 

19 marketable quantities has been disclosed shall be allowed 

20 as a deduction ratably over the 84-month period beginning 

21 on the date that such expenditure was paid or incurred. 

22 ‘‘(b) MID-MONTH CONVENTION.—For purposes of 

23 subsection (a), any expenditures paid or incurred during 

24 any month shall be treated as paid or incurred on the mid25 point of such month. 


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1 ‘‘(c) EXCLUSIVE METHOD.—Except as provided in 

2 this section, no depreciation or amortization deduction 

3 shall be allowed with respect to expenditures described in 

4 subsection (a). 

5 ‘‘(d) TREATMENT UPON ABANDONMENT.—If any 

6 property with respect to which expenditures described in 

7 subsection (a) are paid or incurred is retired or abandoned 

8 during the 84-month period described in such subsection, 

9 no deduction shall be allowed on account of such retire10 ment or abandonment and the amortization deduction 

11 under this section shall continue with respect to such pay12 ment.’’. 

13 (b) CONFORMING AMENDMENTS.— 

14 (1) The item relating to section 616 in the table 

15 of sections for part I of subchapter I of chapter 1 

16 of the Internal Revenue Code of 1986 is amended to 

17 read as follows: 

‘‘Sec. 616. Amortization of development expenditures.’’. 

18 (2) Section 56(a)(2)(A) of such Code is amend19 ed by striking ‘‘616(a) or’’. 

20 (3) Section 59(e) of such Code is amended— 

21 (A) in paragraph (2)— 

22 (i) in subparagraph (C), by inserting 

23 ‘‘or’’ at the end, 

24 (ii) by striking subparagraph (D), and 


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1 (iii) by redesignating subparagraph 

2 (E) as subparagraph (D), and 

3 (B) in paragraph (5)(A), by striking ‘‘, 

4 616(a),’’. 

5 (4) Section 263(a)(1) of such Code is amended 

6 by striking subparagraph (A). 

7 (5) Section 263A(c)(3) of such Code is amend8 ed by striking ‘‘616,’’. 

9 (6) Section 291(b) of such Code is amended— 

10 (A) in paragraph (1)(B), by striking 

11 ‘‘616(a) or’’, 

12 (B) in paragraph (2), by striking ‘‘, 

13 616(a),’’, and 

14 (C) in paragraph (3), by striking ‘‘, 

15 616(a),’’. 

16 (7) Section 312(n)(2)(B) of such Code is 

17 amended by striking ‘‘616(a) or’’. 

18 (8) Section 381(c) of such Code is amended by 

19 striking paragraph (10). 

20 (9) Section 1016(a) of such Code is amended 

21 by striking paragraph (9). 

22 (10) Section 1254(a)(1)(A)(i) of such Code is 

23 amended by striking ‘‘, 616,’’. 

24 (c) EFFECTIVE DATE.—The amendments made by 

25 this section shall apply to expenditures paid or incurred 


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1 in taxable years beginning after the date of the enactment 

2 of this Act. 

3 SEC. 216. AMORTIZATION OF CERTAIN MINING EXPLO4 RATION EXPENDITURES. 

5 (a) IN GENERAL.—Section 617 of the Internal Rev6 enue Code of 1986 is amended to read as follows: 

7 ‘‘SEC. 617. AMORTIZATION OF CERTAIN MINING EXPLO8 RATION EXPENDITURES. 

9 ‘‘(a) IN GENERAL.—Any expenditures paid or in10 curred for the purpose of ascertaining the existence, loca11 tion, extent, or quality of any deposit of ore or other min12 eral, and paid or incurred before the beginning of the de13 velopment stage of the mine, shall be allowed as a deduc14 tion ratably over the 84-month period beginning on the 

15 date that such expense was paid or incurred. 

16 ‘‘(b) MID-MONTH CONVENTION.—For purposes of 

17 subsection (a), any expenditures paid or incurred during 

18 any month shall be treated as paid or incurred on the mid19 point of such month. 

20 ‘‘(c) EXCLUSIVE METHOD.—Except as provided in 

21 this section, no depreciation or amortization deduction 

22 shall be allowed with respect to expenditures described in 

23 subsection (a). 

24 ‘‘(d) TREATMENT UPON ABANDONMENT.—If any 

25 property with respect to which expenditures described in 


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1 subsection (a) are paid or incurred is retired or abandoned 

2 during the 84-month period described in such subsection, 

3 no deduction shall be allowed on account of such retire4 ment or abandonment and the amortization deduction 

5 under this section shall continue with respect to such pay6 ment.’’. 

7 (b) CONFORMING AMENDMENTS.— 

8 (1) The item relating to section 617 in the table 

9 of sections for part I of subchapter I of chapter 1 

10 of the Internal Revenue Code of 1986 is amended to 

11 read as follows: 

‘‘Sec. 617. Amortization of certain mining exploration expenditures.’’. 

12 (2) Section 56(a) of such Code, as amended by 

13 section 215(b)(2), is amended by striking paragraph 

14 (2). 

15 (3) Section 59(e) of such Code, as amended by 

16 section 215(b)(3), is amended— 

17 (A) in paragraph (2)— 

18 (i) in subparagraph (B), by inserting 

19 ‘‘or’’ at the end, 

20 (ii) in subparagraph (C), by striking 

21 the comma at the end and inserting a pe22 riod, and 

23 (iii) by striking subparagraph (D), 

24 and 


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1 (B) by striking paragraph (5) and insert2 ing the following: 

3 ‘‘(5) DISPOSITIONS.—In the case of any dis4 position of property to which section 1254 applies 

5 (determined without regard to this section), any de6 duction under paragraph (1) with respect to 

7 amounts which are allocable to such property shall, 

8 for purposes of section 1254, be treated as a deduc9 tion allowable under section 263(c).’’. 

10 (4) Section 170(e) of such Code is amended— 

11 (A) in paragraph (1), by striking 

12 ‘‘617(d)(1),’’, and 

13 (B) in paragraph (3)(D), by striking 

14 ‘‘617,’’. 

15 (5) Section 263A(c)(3) of such Code, as amend16 ed by section 215(b)(5), is amended by striking 

17 ‘‘291(b)(2), or 617’’ and inserting ‘‘or 291(b)(2)’’. 

18 (6) Section 291(b) of such Code, as amended by 

19 section 215(b)(6), is amended— 

20 (A) in the heading, by striking ‘‘AND MIN21 ERAL EXPLORATION AND DEVELOPMENT

22 COSTS’’, 

23 (B) by striking paragraph (1) and insert24 ing the following: 


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1 ‘‘(1) IN GENERAL.—In the case of an inte2 grated oil company, the amount allowable as a de3 duction for any taxable year (determined without re4 gard to this section) under section 263(c) shall be 

5 reduced by 30 percent.’’, 

6 (C) in paragraph (2), by striking ‘‘or 

7 617(a) (as the case may be)’’, and 

8 (D) in paragraph (3), by striking ‘‘or 

9 617(a) (whichever is appropriate)’’. 

10 (7) Section 312(n), as amended by section 

11 215(b)(7), is amended by striking paragraph (2) and 

12 inserting the following: 

13 ‘‘(2) INTANGIBLE DRILLING COSTS.—Any 

14 amount allowable as a deduction under section 

15 263(c) in determining taxable income (other than 

16 costs incurred in connection with a nonproductive 

17 well)— 

18 ‘‘(A) shall be capitalized, and 

19 ‘‘(B) shall be allowed as a deduction rat20 ably over the 60-month period beginning with 

21 the month in which such amount was paid or 

22 incurred.’’. 

23 (8) Section 703(b) of such Code is amended— 

24 (A) in paragraph (1), by adding ‘‘or’’ at 

25 the end, 


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1 (B) by striking paragraph (2), and 

2 (C) by redesignating paragraph (3) as 

3 paragraph (2). 

4 (9) Section 751(c) of such Code is amended— 

5 (A) by inserting ‘‘, as in effect on the day 

6 before the date of the enactment of the End 

7 Polluter Welfare Act of 2024’’ after ‘‘section 

8 617(f)(2)’’, and 

9 (B) by striking ‘‘617(d)(1),’’. 

10 (10) Section 1254(a)(1)(A)(i) of such Code, as 

11 amended by section 215(b)(10), is amended by strik12 ing ‘‘or 617’’. 

13 (11) Paragraph (2) of section 1363(c) of such 

14 Code is amended to read as follows: 

15 ‘‘(2) EXCEPTION.—In the case of an S corpora16 tion, elections under section 901 (relating to taxes of 

17 foreign countries and possessions of the United 

18 States) shall be made by each shareholder sepa19 rately.’’. 

20 (c) EFFECTIVE DATE.—The amendments made by 

21 this section shall apply to expenditures paid or incurred 

22 in taxable years beginning after the date of the enactment 

23 of this Act. 


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1 SEC. 217. AMORTIZATION OF INTANGIBLE DRILLING AND 

2 DEVELOPMENT COSTS IN THE CASE OF OIL 

3 AND GAS WELLS. 

4 (a) IN GENERAL.—Subsection (c) of section 263 of 

5 the Internal Revenue Code of 1986 is amended to read 

6 as follows: 

7 ‘‘(c) INTANGIBLE DRILLING AND DEVELOPMENT

8 COSTS IN THE CASE OF OIL AND GAS WELLS AND GEO9 THERMAL WELLS.— 

10 ‘‘(1) GEOTHERMAL WELLS.—Notwithstanding 

11 subsection (a), and except as provided in subsection 

12 (i), a taxpayer may elect to deduct as expenses in13 tangible drilling and development costs in the case 

14 of wells drilled for any geothermal deposit (as de15 fined in section 613(e)(2)) in such manner as the 

16 Secretary provides. This subsection shall not apply 

17 with respect to any costs to which any deduction is 

18 allowed under section 59(e). 

19 ‘‘(2) OIL AND GAS WELLS.—Notwithstanding 

20 subsection (a), and except as provided in subsection 

21 (i), in the case of any expenses paid or incurred in 

22 taxable years beginning after the date of the enact23 ment of End Polluter Welfare Act of 2024 in con24 nection with intangible drilling and development 

25 costs related to oil and gas wells— 


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1 ‘‘(A) such expenses shall be allowed as a 

2 deduction ratably over the 84-month period be3 ginning on the date that such expense was paid 

4 or incurred, 

5 ‘‘(B) any such expenses paid or incurred 

6 during any month shall be treated as paid or 

7 incurred on the mid-point of such month, 

8 ‘‘(C) except as provided in this paragraph, 

9 no depreciation or amortization deduction shall 

10 be allowed with respect to such expenses, and 

11 ‘‘(D) if any property with respect to which 

12 such intangible drilling and development costs 

13 are paid or incurred is retired or abandoned 

14 during such 84-month period, no deduction 

15 shall be allowed on account of such retirement 

16 or abandonment and the amortization deduction 

17 under this paragraph shall continue with re18 spect to such payment.’’. 

19 (b) CONFORMING AMENDMENTS.— 

20 (1) Paragraph (2) of section 57(a) of the Inter21 nal Revenue Code of 1986 is amended to read as fol22 lows: 

23 ‘‘(2) INTANGIBLE DRILLING COSTS.— 

24 ‘‘(A) IN GENERAL.—With respect to all 

25 geothermal properties of the taxpayer, the 


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1 amount (if any) by which the amount of the ex2 cess intangible drilling costs arising in the tax3 able year is greater than 65 percent of the net 

4 income of the taxpayer from geothermal prop5 erties for the taxable year. 

6 ‘‘(B) EXCESS INTANGIBLE DRILLING

7 COSTS.—For purposes of subparagraph (A), the 

8 amount of the excess intangible drilling costs 

9 arising in the taxable year is the excess of— 

10 ‘‘(i) the intangible drilling and devel11 opment costs paid or incurred in connec12 tion with geothermal wells (other than 

13 costs incurred in drilling a nonproductive 

14 well) allowable under section 263(c)(1) for 

15 the taxable year, over 

16 ‘‘(ii) the amount which would have 

17 been allowable for the taxable year if such 

18 costs had been capitalized and straight line 

19 recovery of intangibles (as defined in sub20 section (b)) had been used with respect to 

21 such costs. 

22 ‘‘(C) NET INCOME FROM GEOTHERMAL

23 PROPERTIES.—For purposes of subparagraph 

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1 payer from geothermal properties for the tax2 able year is the excess of— 

3 ‘‘(i) the aggregate amount of gross in4 come (within the meaning of section 

5 613(a)) from all geothermal properties of 

6 the taxpayer received or accrued by the 

7 taxpayer during the taxable year, over 

8 ‘‘(ii) the amount of any deductions al9 locable to such properties reduced by the 

10 excess described in subparagraph (B) for 

11 such taxable year.’’. 

12 (2) Section 59(e) of such Code, as amended by 

13 sections 215 and 216, is amended— 

14 (A) in paragraph (2)(C), by striking ‘‘sec15 tion 263(c)’’ and inserting ‘‘section 263(c)(1)’’, 

16 and 

17 (B) in paragraph (5), by striking ‘‘section 

18 263(c)’’ and inserting ‘‘section 263(c)(1)’’. 

19 (3) Section 263A(c)(3) of such Code, as amend20 ed by sections 215 and 216, is amended— 

21 (A) in the heading, by striking ‘‘OIL AND

22 GAS’’ and inserting ‘‘GEOTHERMAL’’, and 

23 (B) by striking ‘‘263(c),’’ and inserting 

24 ‘‘263(c)(1)’’. 


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1 (4) Section 291 of such Code, as amended by 

2 sections 215 and 216, is amended by striking sub3 section (b). 

4 (5) Section 312(n) of such Code, as amended 

5 by sections 215 and 216, is amended by striking 

6 ‘‘section 263(c),’’ and inserting ‘‘section 263(c)(1)’’. 

7 (c) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to expenditures paid or incurred 

9 in taxable years beginning after the date of the enactment 

10 of this Act. 

11 SEC. 218. INCREASE IN EXCISE TAX RATE FOR FUNDING OF 

12 BLACK LUNG DISABILITY TRUST FUND. 

13 (a) IN GENERAL.—Section 4121(b) of the Internal 

14 Revenue Code of 1986 is amended— 

15 (1) in paragraph (1), by striking ‘‘$1.10’’ and 

16 inserting ‘‘$1.38’’, and 

17 (2) in paragraph (2), by striking ‘‘$.55’’ and in18 serting ‘‘$0.69’’. 

19 (b) EFFECTIVE DATE.—The amendments made by 

20 this section shall apply on and after the first day of the 

21 first calendar month beginning after the date of the enact22 ment of this Act. 


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1 SEC. 219. ELIMINATION OF RENEWABLE ELECTRICITY PRO2 DUCTION CREDIT ELIGIBILITY FOR REFINED 

3 COAL. 

4 (a) IN GENERAL.—Section 45 of the Internal Rev5 enue Code of 1986 is amended— 

6 (1) in subsection (b)(2)— 

7 (A) in the first sentence, by striking ‘‘, the 

8 8 cent amount’’ and all that follows through ‘‘in 

9 2002’’ and inserting ‘‘and the 8 cent amount in 

10 paragraph (1)’’, and 

11 (B) in the third sentence, by striking ‘‘In 

12 any other case, if an amount’’ and inserting ‘‘If 

13 the 8 cent amount’’, 

14 (2) in subsection (c), by striking paragraph (7), 

15 (3) in subsection (d), by striking paragraph (8), 

16 and 

17 (4) in subsection (e)— 

18 (A) by striking paragraph (8), and 

19 (B) by striking paragraph (9) and insert20 ing the following: 

21 ‘‘(9) COORDINATION WITH CREDIT FOR PRO22 DUCING FUEL FROM A NONCONVENTIONAL

23 SOURCE.—The term ‘qualified facility’ shall not in24 clude any facility which produces electricity from gas 

25 derived from the biodegradation of municipal solid 

26 waste if such biodegradation occurred in a facility 


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1 (within the meaning of section 45K) the production 

2 from which is allowed as a credit under section 45K 

3 for the taxable year or any prior taxable year.’’. 

4 (b) CONFORMING AMENDMENTS.— 

5 (1) Section 38(c)(4)(B)(iv) of the Internal Rev6 enue Code of 1986 is amended by striking ‘‘or re7 fined coal’’. 

8 (2) Section 45K(g)(2) of such Code is amended 

9 by striking subparagraph (E). 

10 (c) EFFECTIVE DATE.—The amendments made by 

11 this section shall apply to coal produced after December 

12 31, 2024. 

13 SEC. 220. TREATMENT OF FOREIGN OIL RELATED INCOME 

14 AS SUBPART F INCOME. 

15 (a) IN GENERAL.—Section 954(a) of the Internal 

16 Revenue Code of 1986 is amended by striking ‘‘and’’ at 

17 the end of paragraph (2), by striking the period at the 

18 end of paragraph (3) and inserting ‘‘, and’’, and by adding 

19 at the end the following new paragraph: 

20 ‘‘(4) the foreign base company oil related in21 come for the taxable year (determined under sub22 section (f) and reduced as provided in subsection 

23 (b)(5)).’’. 

24 (b) FOREIGN BASE COMPANY OIL RELATED IN25 COME.—Section 954 of the Internal Revenue Code of 1986 


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1 is amended by inserting after subsection (e) the following 

2 new subsection: 

3 ‘‘(f) FOREIGN BASE COMPANY OIL RELATED IN4 COME.—For purposes of this section— 

5 ‘‘(1) IN GENERAL.—Except as otherwise pro6 vided in this subsection, the term ‘foreign base com7 pany oil related income’ means foreign oil related in8 come (within the meaning of paragraphs (2) and (3) 

9 of section 907(c)) other than income derived from a 

10 source within a foreign country in connection with— 

11 ‘‘(A) oil or gas which was extracted from 

12 an oil or gas well located in such foreign coun13 try, or 

14 ‘‘(B) oil, gas, or a primary product of oil 

15 or gas which is sold by the foreign corporation 

16 or a related person for use or consumption 

17 within such country or is loaded in such coun18 try on a vessel or aircraft as fuel for such vessel 

19 or aircraft. 

20 Such term shall not include any foreign personal 

21 holding company income (as defined in subsection 

22 (c)). 

23 ‘‘(2) PARAGRAPH (1) APPLIES ONLY WHERE

24 CORPORATION HAS PRODUCED 1,000 BARRELS PER

25 DAY OR MORE.— 


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1 ‘‘(A) IN GENERAL.—The term ‘foreign 

2 base company oil related income’ shall not in3 clude any income of a foreign corporation if 

4 such corporation is not a large oil producer for 

5 the taxable year. 

6 ‘‘(B) LARGE OIL PRODUCER.—For pur7 poses of subparagraph (A), the term ‘large oil 

8 producer’ means any corporation if, for the tax9 able year or for the preceding taxable year, the 

10 average daily production of foreign crude oil 

11 and natural gas of the related group which in12 cludes such corporation equaled or exceeded 

13 1,000 barrels. 

14 ‘‘(C) RELATED GROUP.—The term ‘related 

15 group’ means a group consisting of the foreign 

16 corporation and any other person who is a re17 lated person with respect to such corporation. 

18 ‘‘(D) AVERAGE DAILY PRODUCTION OF

19 FOREIGN CRUDE OIL AND NATURAL GAS.—For 

20 purposes of this paragraph, the average daily 

21 production of foreign crude oil or natural gas of 

22 any related group for any taxable year (and the 

23 conversion of cubic feet of natural gas into bar24 rels) shall be determined under rules similar to 

25 the rules of section 613A (as in effect on the 


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1 day before the date of enactment of the End 

2 Polluter Welfare Act of 2024) except that only 

3 crude oil or natural gas from a well located out4 side the United States shall be taken into ac5 count.’’. 

6 (c) CONFORMING AMENDMENTS.— 

7 (1) Section 952(c)(1)(B)(iii) of the Internal 

8 Revenue Code of 1986 is amended by redesignating 

9 subclauses (I) through (IV) as subclauses (II) 

10 through (V), respectively, and by inserting before 

11 subclause (II) (as so redesignated) the following: 

12 ‘‘(I) foreign base company oil re13 lated income,’’. 

14 (2) Section 954(b) of such Code is amended— 

15 (A) by inserting at the end of paragraph 

16 (4) the following: ‘‘The preceding sentence shall 

17 not apply to foreign base company oil-related 

18 income described in subsection (a)(4).’’, 

19 (B) by striking ‘‘and the foreign base com20 pany services income’’ in paragraph (5) and in21 serting ‘‘the foreign base company services in22 come, and the foreign base company oil related 

23 income’’, and 

24 (C) by adding at the end the following new 

25 paragraph: 


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1 ‘‘(6) FOREIGN BASE COMPANY OIL RELATED IN2 COME NOT TREATED AS ANOTHER KIND OF BASE

3 COMPANY INCOME.—Income of a corporation which 

4 is foreign base company oil related income shall not 

5 be considered foreign base company income of such 

6 corporation under paragraph (2) or (3) of subsection 

7 (a).’’. 

8 (d) EFFECTIVE DATE.—The amendments made by 

9 this section shall apply to taxable years of foreign corpora10 tions beginning after the date of the enactment of this 

11 Act and to taxable years of United States shareholders 

12 ending with or within which such taxable years of foreign 

13 corporations end. 

14 SEC. 221. REPEAL OF EXCLUSION OF FOREIGN OIL AND 

15 GAS EXTRACTION INCOME FROM THE DETER16 MINATION OF TESTED INCOME. 

17 (a) IN GENERAL.—Section 951A(c)(2)(A)(i) of the 

18 Internal Revenue Code of 1986 is amended— 

19 (1) by adding ‘‘and’’ at the end of subclause 

20 (III), 

21 (2) by striking ‘‘and’’ at the end of subclause 

22 (IV) and inserting ‘‘over’’, and 

23 (3) by striking subclause (V). 

24 (b) EFFECTIVE DATE.—The amendments made by 

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1 tions beginning after the date of enactment of this Act, 

2 and to taxable years of United States shareholders in 

3 which or with which such taxable years of foreign corpora4 tions end. 

5 SEC. 222. TERMINATION OF CREDIT FOR CARBON OXIDE 

6 SEQUESTRATION. 

7 (a) IN GENERAL.—Section 45Q of the Internal Rev8 enue Code of 1986 is amended by adding at the end the 

9 following: 

10 ‘‘(j) TERMINATION.—This section shall not apply 

11 with respect to any qualified carbon oxide captured after 

12 the date of enactment of the End Polluter Welfare Act 

13 of 2024.’’. 

14 (b) REPORT.— 

15 (1) IN GENERAL.—Not later than 6 months 

16 after the date of enactment of this Act, the Sec17 retary of the Treasury, or the Secretary’s delegate, 

18 shall submit a report to Congress, to be made avail19 able to the public, which provides the following infor20 mation: 

21 (A) The taxpayer identity information of 

22 any taxpayer for which the carbon oxide seques23 tration credit under section 45Q of the Internal 

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1 able year following the enactment of such sec2 tion. 

3 (B) The total amount of the credit allowed 

4 pursuant to such section to each taxpayer de5 scribed in subparagraph (A). 

6 (C) With respect to the amount described 

7 in subparagraph (B), the amount of such credit 

8 allowed with respect to each of the following: 

9 (i) Qualified carbon oxide which was 

10 captured and disposed of by the taxpayer 

11 in secure geological storage and not used 

12 by the taxpayer as described in clause (ii) 

13 or (iii). 

14 (ii) Qualified carbon oxide which was 

15 captured and used by the taxpayer as a 

16 tertiary injectant in a qualified enhanced 

17 oil or natural gas recovery project and dis18 posed of by the taxpayer in secure geologi19 cal storage. 

20 (iii) Qualified carbon oxide which was 

21 captured and utilized by the taxpayer in a 

22 manner described in section 45Q(f)(5) of 

23 the Internal Revenue Code of 1986. 

24 (2) EXCEPTION FROM RULES REGARDING CON25 FIDENTIALITY AND DISCLOSURE OF RETURNS AND


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1 RETURN INFORMATION.—Section 6103(l) of the In2 ternal Revenue Code of 1986 is amended by adding 

3 at the end the following: 

4 ‘‘(23) DISCLOSURE OF RETURN INFORMATION

5 FOR PUBLIC REPORT ON CARBON OXIDE SEQUES6 TRATION CREDIT.—The Secretary may disclose tax7 payer identity information and return information to 

8 the extent the Secretary deems necessary for pur9 poses of the report issued pursuant to section 222 

10 of the End Polluter Welfare Act of 2024.’’. 

11 SEC. 223. ELIMINATE DRAWBACKS ON PETROLEUM TAXES. 

12 (a) IN GENERAL.—Section 313(j) of the Tariff Act 

13 of 1930 (19 U.S.C. 1313(j)) is amended by adding at the 

14 end the following new paragraph: 

15 ‘‘(7) No amount of any tax imposed on any merchan16 dise pursuant to section 4611 of the Internal Revenue 

17 Code of 1986 shall be eligible to be refunded as drawback 

18 under this subsection.’’. 

19 (b) EFFECTIVE DATE.—The amendment made by 

20 this section shall apply with respect to articles entered, 

21 or withdrawn from warehouse for consumption, on or after 

22 January 1, 2025. 


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1 SEC. 224. MODIFYING CLEAN HYDROGEN PRODUCTION 

2 CREDIT. 

3 (a) IN GENERAL.—Section 45V of the Internal Rev4 enue Code of 1986 is amended— 

5 (1) in subsection (a), by striking paragraph (2) 

6 and inserting the following: 

7 ‘‘(2) $0.60.’’, 

8 (2) by striking subsection (b) and inserting the 

9 following: 

10 ‘‘(b) INFLATION ADJUSTMENT.—The $0.60 amount 

11 in subsection (a)(2) shall be adjusted by multiplying such 

12 amount by the inflation adjustment factor (as determined 

13 under section 45(e)(2), determined by substituting ‘2023’ 

14 for ‘1992’ in subparagraph (B) thereof) for the calendar 

15 year in which the qualified clean hydrogen is produced. 

16 If any amount as increased under the preceding sentence 

17 is not a multiple of 0.1 cent, such amount shall be rounded 

18 to the nearest multiple of 0.1 cent.’’, 

19 (3) in subsection (c)— 

20 (A) by striking paragraph (1), 

21 (B) in paragraph (2)— 

22 (i) by striking subparagraph (A) and 

23 inserting the following: 

24 ‘‘(A) DEFINITION.— 

25 ‘‘(i) IN GENERAL.—The term ‘quali26 fied clean hydrogen’ means hydrogen proVerDate Sep 11 2014 02:16 Sep 21, 2024 Jkt 049200 PO 00000 Frm 00061 Fmt 6652 Sfmt 6201 E:\BILLS\H8554.IH H8554

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1 duced using an electrolyzer for which the 

2 electricity used is— 

3 ‘‘(I) produced at a facility 

4 which— 

5 ‘‘(aa) uses qualified renew6 able energy resources to produce 

7 such electricity, 

8 ‘‘(bb) was placed in service 

9 not greater than 36 months prior 

10 to the date on which the facility 

11 which produces such hydrogen 

12 was placed in service, and 

13 ‘‘(cc) is in the same region 

14 (as defined in the National 

15 Transmission Needs Study of the 

16 Department of Energy, dated Oc17 tober 30, 2023) as the facility 

18 which produces such hydrogen, 

19 and 

20 ‘‘(II) produced at the facility de21 scribed in subclause (I) not less than 

22 1 hour prior to use by the electrolyzer. 

23 ‘‘(ii) QUALIFIED RENEWABLE ENERGY

24 RESOURCES.—The term ‘qualified renew25 able energy resources’ means— 


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1 ‘‘(I) wind, 

2 ‘‘(II) solar energy, 

3 ‘‘(III) geothermal energy (as de4 fined in section 45(c)(4)), 

5 ‘‘(IV) marine and hydrokinetic 

6 renewable energy (as defined in sec7 tion 45(c)(10)), and 

8 ‘‘(V) hydropower.’’, and 

9 (ii) by striking subparagraph (C), 

10 (C) in paragraph (3)(C), by inserting ‘‘, 

11 and which is placed in service after December 

12 31, 2024’’ after ‘‘January 1, 2033’’, and 

13 (D) by redesignating paragraphs (2) and 

14 (3) as paragraphs (1) and (2), respectively, 

15 (4) in subsection (e)— 

16 (A) in paragraph (1), by striking ‘‘de17 scribed in subsection (b)(2)’’ and inserting 

18 ‘‘produced by the taxpayer’’, and 

19 (B) in paragraph (3)(A)(ii), by striking 

20 ‘‘subsection (a)(2)’’ and inserting ‘‘subsection 

21 (a)(1)’’, and 

22 (5) in subsection (f), by striking ‘‘, including 

23 regulations or other guidance for determining 

24 lifecycle greenhouse gas emissions’’. 

25 (b) CONFORMING AMENDMENTS.— 


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1 (1) Section 45(e)(13) of the Internal Revenue 

2 Code of 1986 is amended by striking ‘‘section 

3 45V(c)(3)) to produce qualified clean hydrogen (as 

4 defined in section 45V(c)(2))’’ and inserting ‘‘section 

5 45V(c)(2)) to produce qualified clean hydrogen (as 

6 defined in section 45V(c)(1))’’. 

7 (2) Section 48(a)(15) of such Code is amend8 ed— 

9 (A) in subparagraph (A), by striking 

10 clause (ii) and inserting the following: 

11 ‘‘(ii) the energy percentage with re12 spect to such property is 6 percent.’’, 

13 (B) in subparagraph (C)— 

14 (i) by striking ‘‘section 45V(c)(3)’’ 

15 and inserting ‘‘section 45V(c)(2)’’, and 

16 (ii) in clause (i), by striking ‘‘Decem17 ber 31, 2022’’ and inserting ‘‘December 

18 31, 2024’’, and 

19 (C) in subparagraph (D), by striking ‘‘sec20 tion 45V(c)(2)’’ and inserting ‘‘section 

21 45V(c)(1)’’. 

22 (3) Section 6417 of such Code is amended— 

23 (A) in subsection (b)(5), by striking ‘‘De24 cember 31, 2012’’ and inserting ‘‘December 31, 

25 2024’’, and 


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1 (B) in subsection (d)(1)(B), by striking 

2 ‘‘section 45V(c)(3)’’ and inserting ‘‘section 

3 45V(c)(2)’’. 

4 (c) EFFECTIVE DATE.—The amendments made by 

5 this section shall apply to facilities placed in service after 

6 December 31, 2024. 

7 TITLE III—REPEAL RECENT FOS8 SIL FUEL SUBSIDY LEGISLA9 TION 

10 SEC. 301. FISCAL RESPONSIBILITY ACT. 

11 (a) BUILDER ACT.— 

12 (1) GENERAL REPEAL.—Sections 106, 107, 

13 108, 109, 110, and 111 of the National Environ14 mental Policy Act of 1969 (42 U.S.C. 4336, 4336a, 

15 4336b, 4336c, 4336d, 4336e) are repealed. 

16 (2) REPEAL OF MODIFICATIONS.—Section 

17 102(2) of the National Environmental Policy Act of 

18 1969 (42 U.S.C. 4332(2)) is amended— 

19 (A) in subparagraph (C)— 

20 (i) in the matter preceding clause (i), 

21 by striking ‘‘consistent with the provisions 

22 of this Act and except where compliance 

23 would be inconsistent with other statutory 

24 requirements,’’; 


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1 (ii) by striking clauses (i) through (v) 

2 and inserting the following: 

3 ‘‘(i) the environmental impact of the 

4 proposed action; 

5 ‘‘(ii) any adverse environmental ef6 fects which cannot be avoided should the 

7 proposal be implemented; 

8 ‘‘(iii) alternatives to the proposed ac9 tion; 

10 ‘‘(iv) the relationship between local 

11 short-term uses of man’s environment and 

12 the maintenance and enhancement of long13 term productivity; and 

14 ‘‘(v) any irreversible and irretrievable 

15 commitments of resources which would be 

16 involved in the proposed action should it be 

17 implemented.’’; and 

18 (iii) in the undesignated matter fol19 lowing clause (v) (as so amended), in the 

20 first sentence, by striking ‘‘head of the 

21 lead agency’’ and inserting ‘‘responsible 

22 Federal official’’; 

23 (B) by striking subparagraphs (D), (E), 

24 and (F); 


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1 (C) by redesignating subparagraphs (G) 

2 through (L) as subparagraphs (D) through (I); 

3 and 

4 (D) in subparagraph (F) (as so redesig5 nated), by striking ‘‘consistent with the provi6 sions of this Act,’’. 

7 (b) EXPEDITING COMPLETION OF THE MOUNTAIN

8 VALLEY PIPELINE.—Section 324 of the Fiscal Responsi9 bility Act (Public Law 118–5; 137 Stat. 47) is repealed. 

10 SEC. 302. INFLATION REDUCTION ACT. 

11 (a) 2017–2022 OUTER CONTINENTAL SHELF LEAS12 ING PROGRAM.—Section 50264 of Public Law 117–169 

13 (commonly known as the ‘‘Inflation Reduction Act of 

14 2022’’) (136 Stat. 2059) is repealed. 

15 (b) ENSURING ENERGY SECURITY.—Section 50265 

16 of Public Law 117–169 (commonly known as the ‘‘Infla17 tion Reduction Act of 2022’’) (43 U.S.C. 3006) is re18 pealed. 

19 TITLE IV—ELIMINATION OF 

20 OTHER FOSSIL FUEL SUBSIDIES 

21 SEC. 401. STUDY AND ELIMINATION OF ADDITIONAL FOSSIL 

22 FUEL SUBSIDIES. 

23 (a) DEFINITION OF SUBSIDY FOR FOSSIL-FUEL PRO24 DUCTION.—In this section, the term ‘‘subsidy for fossil25 fuel production’’ means any direct funding, tax treatment 


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1 or incentive, risk-reduction benefit, financing assistance or 

2 guarantee, royalty relief, or other provision that provides 

3 a financial benefit to a fossil-fuel company for the produc4 tion of fossil fuels. 

5 (b) REPORT TO CONGRESS.—Not later than 1 year 

6 after the date of enactment of this Act, the Secretary of 

7 the Treasury or a delegate of the Secretary (referred to 

8 in this section as the ‘‘Secretary’’), in coordination with 

9 the Secretary of Energy, shall submit to Congress a report 

10 detailing each Federal law (including regulations), other 

11 than those amended by this Act, as in effect on the date 

12 on which the report is submitted, that includes a subsidy 

13 for fossil-fuel production. 

14 (c) REPORT ON MODIFIED RECOVERY PERIOD.— 

15 (1) IN GENERAL.—Not later than 1 year after 

16 the date of enactment of this Act, the Secretary, in 

17 coordination with the Commissioner of Internal Rev18 enue, shall submit to Congress a report on the appli19 cable recovery period under the accelerated cost re20 covery system provided in section 168 of the Inter21 nal Revenue Code of 1986 for each type of property 

22 involved in fossil-fuel production, including pipelines, 

23 power generation property, refineries, and drilling 

24 equipment, to determine if any assets are receiving 

25 a subsidy for fossil-fuel production. 


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1 (2) ELIMINATION OF SUBSIDY.— 

2 (A) IN GENERAL.—In the case of any type 

3 of property that the Secretary determines is re4 ceiving a subsidy for fossil-fuel production 

5 under section 168 of the Internal Revenue Code 

6 of 1986, for property placed in service in tax7 able years beginning after the date of such de8 termination, section 168 of the Internal Rev9 enue Code of 1986 shall not apply. 

10 (B) EXCEPTION.—Subparagraph (A) shall 

11 not apply to any property with respect to a tax12 able year unless such determination is published 

13 before the first day of such taxable year. 

Æ 


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