I 

113TH CONGRESS 

2D SESSION H. R. 4753 

To amend the Internal Revenue Code of 1986 to provide incentives for 

clean energy and to repeal fossil fuel subsidies for big oil companies. 

IN THE HOUSE OF REPRESENTATIVES 

MAY 28, 2014 

Mr. MCDERMOTT (for himself, Mr. WAXMAN, Mr. LARSON of Connecticut, Mr. 

BLUMENAUER, and Mr. PASCRELL) introduced the following bill; which 

was referred to the Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to provide 

incentives for clean energy and to repeal fossil fuel subsidies for big oil companies. 

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; TABLE OF CONTENTS. 

4 (a) SHORT TITLE.—This Act may be cited as the 

5 ‘‘Investing to Modernize the Production of American 

6 Clean Energy and Technology Act of 2014’’ or as the 

7 ‘‘IMPACT Act of 2014’’. 

8 (b) TABLE OF CONTENTS.—The table of contents of 

9 this Act is as follows: 


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Sec. 1. Short title; table of contents. 

TITLE I—CLEAN ENERGY INCENTIVES 

Subtitle A—Renewable Energy 

Sec. 101. Extension of renewable energy credits. 

Sec. 102. Extension of election of investment tax credit in lieu of production 

credit. 

Sec. 103. Extension of qualifying advanced energy project credit. 

Sec. 104. Extension of credit for energy-efficient new homes. 

Sec. 105. Extension of credit for energy-efficient appliances. 

Subtitle B—Electric, Natural Gas, and Hydrogen Vehicles 

Sec. 111. Increase and expansion of credit for qualified plug-in electric drive 

motor vehicles. 

Sec. 112. Extension of new qualified alternative fuel motor vehicle credit for 

heavy natural gas vehicles. 

Sec. 113. Modification of credit for alternative fuel vehicle refueling property 

for vehicles powered by electricity, natural gas, or hydrogen. 

Sec. 114. Electric, natural gas, and hydrogen vehicle refueling property tax 

credit bonds. 

TITLE II—REPEAL OF FOSSIL FUEL SUBSIDIES FOR BIG OIL 

COMPANIES 

Sec. 201. Prohibition on using last-in, first-out accounting for major integrated 

oil companies. 

Sec. 202. Modifications of foreign tax credit rules applicable to major integrated oil companies which are dual capacity taxpayers. 

Sec. 203. Limitation on section 199 deduction attributable to oil, natural gas, 

or primary products thereof. 

Sec. 204. Limitation on deduction for intangible drilling and development costs. 

Sec. 205. Limitation on percentage depletion allowance for oil and gas wells. 

Sec. 206. Limitation on deduction for tertiary injectants. 

1 TITLE I—CLEAN ENERGY 

2 INCENTIVES 

3 Subtitle A—Renewable Energy 

4 SEC. 101. EXTENSION OF RENEWABLE ENERGY CREDITS. 

5 (a) WIND, BIOMASS, GEOTHERMAL, SMALL IRRIGA6 TION, LANDFILL GAS, HYDROPOWER, MARINE, AND

7 HYDROKINETIC.—Each of the following provisions of sec8 tion 45(d) of such Code is amended by striking ‘‘January 


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1 1, 2014’’ each place it appears and inserting ‘‘January 

2 1, 2024’’: 

3 (1) Paragraph (1). 

4 (2) Clauses (i) and (ii) of paragraph (2)(A). 

5 (3) Clauses (i)(I) and (ii) of paragraph (3)(A). 

6 (4) Paragraph (4). 

7 (5) Paragraph (6). 

8 (6) Subparagraphs (A) and (C) of paragraph 

9 (9). 

10 (7) Subparagraph (B) of paragraph (11). 

11 (b) EARLY TERMINATION IN EVENT OF FEDERAL

12 RENEWABLE ELECTRICITY REQUIREMENT.—Subsection 

13 (d) of section 45 of the Internal Revenue Code of 1986 

14 is amended by adding at the end the following new para15 graph: 

16 ‘‘(12) TERMINATION IN EVENT OF FEDERAL

17 RENEWABLE ELECTRICITY REQUIREMENT.—Not18 withstanding any other provision of this section, the 

19 term ‘qualified facility’ shall not include any prop20 erty which is placed in service after the date which 

21 is 1 year after the date on which the Secretary of 

22 Energy makes a public declaration that a Federal 

23 law is in effect which requires retail electric sup24 pliers in the United States to supply minimum and 

25 significant amounts of electric energy which is genVerDate Mar 15 2010 23:07 Jun 03, 2014 Jkt 039200 PO 00000 Frm 00003 Fmt 6652 Sfmt 6201 E:\BILLS\H4753.IH H4753

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1 erated from renewable sources to customers for pur2 poses other than resale.’’. 

3 SEC. 102. EXTENSION OF ELECTION OF INVESTMENT TAX 

4 CREDIT IN LIEU OF PRODUCTION CREDIT. 

5 (a) IN GENERAL.—Clause (ii) of section 48(a)(5)(C) 

6 of the Internal Revenue Code of 1986 is amended by strik7 ing ‘‘January 1, 2014’’ and inserting ‘‘January 1, 2024’’. 

8 (b) LIMITATION.—Paragraph (5) of section 48(a) of 

9 such Code is amended by adding at the end the following 

10 new subparagraphs: 

11 ‘‘(E) LIMITATION.—In the case of a quali12 fying offshore wind facility to which this para13 graph applies and the total megawatt name14 plate capacity of which exceeds 3,000 

15 megawatts, the basis which would (but for this 

16 subparagraph) be taken into account under sub17 section (a) with respect to such facility shall not 

18 exceed the amount which bears the same ratio 

19 to such basis as— 

20 ‘‘(i) 3000 megawatts, bears to 

21 ‘‘(ii) the total megawatt nameplate ca22 pacity of such facility. 

23 ‘‘(F) QUALIFYING OFFSHORE WIND FACIL24 ITY.—For purposes of this paragraph— 


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1 ‘‘(i) IN GENERAL.—The term ‘quali2 fying offshore wind facility’ means an off3 shore facility using wind to produce elec4 tricity. 

5 ‘‘(ii) OFFSHORE FACILITY.—The term 

6 ‘offshore facility’ means any facility located 

7 in the inland navigable waters of the 

8 United States, including the Great Lakes, 

9 or in the coastal waters of the United 

10 States, including the territorial seas of the 

11 United States, the exclusive economic zone 

12 of the United States, and the Outer Conti13 nental Shelf of the United States. For pur14 poses of the preceding sentence, the term 

15 ‘United States’ has the meaning given in 

16 section 638(1).’’. 

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

18 this section shall apply to facilities placed in service after 

19 December 31, 2013. 

20 SEC. 103. EXTENSION OF QUALIFYING ADVANCED ENERGY 

21 PROJECT CREDIT. 

22 Paragraph (1) of section 48C(d) of the Internal Rev23 enue Code of 1986 is amended by adding at the end the 

24 following new subparagraph: 

25 ‘‘(C) ADDITIONAL LIMITATION AMOUNT.— 


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1 ‘‘(i) IN GENERAL.—The total amount 

2 of credits that may be allocated under the 

3 program shall be increased by 

4 $5,000,000,000. 

5 ‘‘(ii) APPLICATIONS.—Notwith6 standing the deadline for submitting appli7 cations specified in paragraph (2)(A), an 

8 applicant for certification with respect to 

9 credits allocated pursuant to clause (i) may 

10 submit an application to the Secretary at 

11 such time and in such manner as the Sec12 retary may provide. 

13 ‘‘(iii) REVIEW, REDISTRIBUTION, AND

14 REALLOCATION.—Notwithstanding the 

15 deadline for review specified in paragraph 

16 (4)(A), the Secretary shall review the cred17 its allocated pursuant to clause (i) at such 

18 time as the Secretary determines appro19 priate.’’. 

20 SEC. 104. EXTENSION OF CREDIT FOR ENERGY-EFFICIENT 

21 NEW HOMES. 

22 (a) IN GENERAL.—Subsection (g) of section 45L of 

23 the Internal Revenue Code of 1986 is amended by striking 

24 ‘‘December 31, 2013’’ and inserting ‘‘December 31, 

25 2016’’. 


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

2 this section shall apply to homes acquired after December 

3 31, 2013. 

4 SEC. 105. EXTENSION OF CREDIT FOR ENERGY-EFFICIENT 

5 APPLIANCES. 

6 (a) IN GENERAL.—Section 45M(b) of the Internal 

7 Revenue Code of 1986 is amended by striking ‘‘or 2013’’ 

8 each place it appears and inserting ‘‘2013, 2014, 2015, 

9 or 2016’’. 

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

11 this section shall apply to appliances produced after De12 cember 31, 2013. 

13 Subtitle B—Electric, Natural Gas, 

14 and Hydrogen Vehicles 

15 SEC. 111. INCREASE AND EXPANSION OF CREDIT FOR 

16 QUALIFIED PLUG-IN ELECTRIC DRIVE MOTOR 

17 VEHICLES. 

18 (a) INCREASE IN DOLLAR LIMITATION.—Paragraph 

19 (2) of section 30D(b) of the Internal Revenue Code of 

20 1986 is amended by striking ‘‘$2,500’’ and inserting 

21 ‘‘$5,000’’. 

22 (b) INCREASE IN LIMITATION ON NUMBER OF VEHI23 CLES ELIGIBLE FOR CREDIT.—Paragraph (2) of section 

24 30D(e) of such Code is amended by striking ‘‘200,000’’ 

25 and inserting ‘‘400,000’’. 


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

2 this section shall apply to vehicles acquired after the date 

3 of the enactment of this Act. 

4 SEC. 112. EXTENSION OF NEW QUALIFIED ALTERNATIVE 

5 FUEL MOTOR VEHICLE CREDIT FOR HEAVY 

6 NATURAL GAS VEHICLES. 

7 (a) IN GENERAL.—Paragraph (4) of section 30B(k) 

8 of the Internal Revenue Code of 1986 is amended by in9 serting ‘‘(December 31, 2018, in the case of a vehicle pow10 ered by compressed or liquefied natural gas and weighing 

11 more than 8,500 pounds)’’ before the period at the end. 

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

13 this section shall apply to vehicles purchased after the date 

14 of the enactment of this Act. 

15 SEC. 113. MODIFICATION OF CREDIT FOR ALTERNATIVE 

16 FUEL VEHICLE REFUELING PROPERTY FOR 

17 VEHICLES POWERED BY ELECTRICITY, NAT18 URAL GAS, OR HYDROGEN. 

19 (a) SPECIAL RULES FOR PROPERTY PLACED IN

20 SERVICE BEFORE JANUARY 1, 2021.—Subsection (e) of 

21 section 30C of the Internal Revenue Code of 1986 is 

22 amended by adding at the end the following new para23 graph: 

24 ‘‘(7) PROPERTY FOR RECHARGING VEHICLES

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1 DROGEN.—In the case of property placed in service 

2 after December 31, 2013, and before January 1, 

3 2021, which relates to electricity, natural gas, or hy4 drogen— 

5 ‘‘(A) subsection (a) shall be applied by 

6 substituting ‘50 percent’ for ‘30 percent’, 

7 ‘‘(B) subsection (b)(1) shall be applied by 

8 substituting ‘$50,000’ for ‘$30,000’, and 

9 ‘‘(C) subsection (b)(2) shall be applied by 

10 substituting ‘$2,000’ for ‘$1,000’.’’. 

11 (b) INSTALLATION COSTS.—Subsection (e) of section 

12 30C of such Code, as amended by subsection (a), is 

13 amended by adding at the end the following: 

14 ‘‘(8) INSTALLATION COSTS.—The cost of any 

15 qualified alternative fuel vehicle refueling property 

16 which relates to electricity, natural gas, or hydrogen 

17 shall include the cost of the original installation of 

18 such property.’’. 

19 (c) TERMINATION OF CREDIT.—Paragraph (1) of 

20 section 30C(g) of such Code is amended to read as follows: 

21 ‘‘(1) in the case of property relating to elec22 tricity, natural gas, or hydrogen, after December 31, 

23 2020, and’’. 


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

2 this section shall apply to property placed in service after 

3 December 31, 2013. 

4 SEC. 114. ELECTRIC, NATURAL GAS, AND HYDROGEN VEHI5 CLE REFUELING PROPERTY TAX CREDIT 

6 BONDS. 

7 (a) IN GENERAL.—Paragraph (1) of section 54A(d) 

8 of the Internal Revenue Code of 1986 is amended by strik9 ing ‘‘or’’ at the end of subparagraph (D), by inserting 

10 ‘‘or’’ at the end of subparagraph (E), and by inserting 

11 after subparagraph (E) the following new subparagraph: 

12 ‘‘(F) a qualified electric, natural gas, and 

13 hydrogen vehicle refueling property bond,’’. 

14 (b) QUALIFIED PURPOSE.—Subparagraph (C) of sec15 tion 54A(d)(2) of such Code is amended by striking ‘‘and’’ 

16 at the end of clause (iv), by striking the period at the end 

17 of clause (v) and inserting ‘‘, and’’, and by adding at the 

18 end the following new clause: 

19 ‘‘(vi) in the case of a qualified electric, 

20 natural gas, and hydrogen vehicle refueling 

21 property bond, a purpose specified in sec22 tion 54G(a)(1).’’. 

23 (c) BONDS ALLOWED.—Subpart I of part IV of sub24 chapter A of chapter 1 of such Code is amended by adding 

25 at the end the following new section: 


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1 ‘‘SEC. 54G. QUALIFIED ELECTRIC, NATURAL GAS, AND HY2 DROGEN VEHICLE REFUELING PROPERTY 

3 BONDS. 

4 ‘‘(a) QUALIFIED ELECTRIC, NATURAL GAS, AND HY5 DROGEN VEHICLE REFUELING PROPERTY BOND.—For 

6 purposes of this subpart, the term ‘qualified electric, nat7 ural gas, and hydrogen vehicle refueling property bond’ 

8 means any bond issued as part of an issue if— 

9 ‘‘(1) 100 percent of the available project pro10 ceeds of such issue are to be used for capital expend11 itures incurred by a qualified issuer for 1 or more 

12 qualified electric, natural gas, and hydrogen vehicle 

13 refueling properties, 

14 ‘‘(2) the bond is issued by a qualified issuer, 

15 and 

16 ‘‘(3) the issuer designates such bond for pur17 poses of this section. 

18 ‘‘(b) REDUCED CREDIT AMOUNT.—Notwithstanding 

19 paragraph (2) of section 54A(b), the annual credit deter20 mined with respect to any qualified electric, natural gas, 

21 and hydrogen vehicle refueling property bond is 70 percent 

22 of the amount which would (but for this subsection) other23 wise be determined under such paragraph with respect to 

24 such bond. 

25 ‘‘(c) LIMITATION ON AMOUNT OF BONDS DES26 IGNATED.—The maximum aggregate face amount of 


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1 bonds which may be designated under subsection (a) by 

2 any issuer shall not exceed the limitation amount allocated 

3 to such issuer under subsection (e). 

4 ‘‘(d) NATIONAL LIMITATION ON AMOUNT OF BONDS

5 DESIGNATED.—There is a national qualified electric, nat6 ural gas, and hydrogen vehicle refueling property bond 

7 limitation of $750,000,000. 

8 ‘‘(e) ALLOCATIONS.—The Secretary shall make allo9 cations of the amount of the national qualified electric, 

10 natural gas, and hydrogen vehicle refueling property bond 

11 limitation described in subsection (d) among purposes de12 scribed in subsection (a)(1) in such manner as the Sec13 retary determines appropriate. 

14 ‘‘(f) DEFINITIONS.—For purposes of this section— 

15 ‘‘(1) QUALIFIED ELECTRIC, NATURAL GAS, AND

16 HYDROGEN VEHICLE REFUELING PROPERTY.—The 

17 term ‘qualified electric, natural gas, and hydrogen 

18 vehicle refueling property’ means any qualified alter19 native fuel vehicle refueling property (within the 

20 meaning of section 30C) which relates to electricity, 

21 natural gas, or hydrogen. 

22 ‘‘(2) QUALIFIED ISSUER.— 

23 ‘‘(A) IN GENERAL.—The term ‘qualified 

24 issuer’ means a public power provider, a cooper25 ative electric company, or a governmental body. 


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1 ‘‘(B) GOVERNMENTAL BODY.—The term 

2 ‘governmental body’ means any State or Indian 

3 tribal government, or any political subdivision 

4 thereof. 

5 ‘‘(C) PUBLIC POWER PROVIDER.—The 

6 term ‘public power provider’ means a State util7 ity that has a service obligation to end-users or 

8 to a distribution utility (within the meaning of 

9 section 217 of the Federal Power Act, as in ef10 fect on the date of the enactment of this sec11 tion). 

12 ‘‘(D) COOPERATIVE ELECTRIC COMPANY.— 

13 The term ‘cooperative electric company’ means 

14 a mutual or cooperative electric company de15 scribed in section 501(c)(12) or an organization 

16 described in section 1381(a)(2)(C).’’. 

17 (d) CLERICAL AMENDMENT.—The table of sections 

18 for subpart I of part IV of subchapter A of chapter 1 of 

19 the Internal Revenue Code of 1986 is amended by adding 

20 at the end the following new item: 

‘‘Sec. 54G. Qualified electric, natural gas, and hydrogen vehicle refueling property bonds.’’. 

21 (e) EFFECTIVE DATE.—The amendments made by 

22 this section shall apply to obligations issued after the date 

23 of the enactment of this Act. 


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1 TITLE II—REPEAL OF FOSSIL 

2 FUEL SUBSIDIES FOR BIG OIL 

3 COMPANIES 

4 SEC. 201. PROHIBITION ON USING LAST-IN, FIRST-OUT AC5 COUNTING FOR MAJOR INTEGRATED OIL 

6 COMPANIES. 

7 (a) IN GENERAL.—Section 472 of the Internal Rev8 enue Code of 1986 is amended by adding at the end the 

9 following new subsection: 

10 ‘‘(h) MAJOR INTEGRATED OIL COMPANIES.—Not11 withstanding any other provision of this section, a major 

12 integrated oil company (as defined in section 

13 167(h)(5)(B)) may not use the method provided in sub14 section (b) in inventorying of any goods.’’. 

15 (b) EFFECTIVE DATE AND SPECIAL RULE.— 

16 (1) IN GENERAL.—The amendment made by 

17 subsection (a) shall apply to taxable years beginning 

18 after the date of the enactment of this Act. 

19 (2) CHANGE IN METHOD OF ACCOUNTING.—In 

20 the case of any taxpayer required by the amendment 

21 made by this section to change its method of ac22 counting for its first taxable year beginning after the 

23 date of the enactment of this Act— 

24 (A) such change shall be treated as initi25 ated by the taxpayer, 


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1 (B) such change shall be treated as made 

2 with the consent of the Secretary of the Treas3 ury, and 

4 (C) the net amount of the adjustments re5 quired to be taken into account by the taxpayer 

6 under section 481 of the Internal Revenue Code 

7 of 1986 shall be taken into account ratably over 

8 a period (not greater than 8 taxable years) be9 ginning with such first taxable year. 

10 SEC. 202. MODIFICATIONS OF FOREIGN TAX CREDIT RULES 

11 APPLICABLE TO MAJOR INTEGRATED OIL 

12 COMPANIES WHICH ARE DUAL CAPACITY 

13 TAXPAYERS. 

14 (a) IN GENERAL.—Section 901 of the Internal Rev15 enue Code of 1986 is amended by redesignating subsection 

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

17 the following new subsection: 

18 ‘‘(n) SPECIAL RULES RELATING TO MAJOR INTE19 GRATED OIL COMPANIES WHICH ARE DUAL CAPACITY

20 TAXPAYERS.— 

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

22 other provision of this chapter, any amount paid or 

23 accrued by a dual capacity taxpayer which is a 

24 major integrated oil company (as defined in section 

25 167(h)(5)(B)) to a foreign country or possession of 


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1 the United States for any period shall not be consid2 ered a tax— 

3 ‘‘(A) if, for such period, the foreign coun4 try or possession does not impose a generally 

5 applicable income tax, or 

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

7 the amount (determined in accordance with reg8 ulations) which— 

9 ‘‘(i) is paid by such dual capacity tax10 payer pursuant to the generally applicable 

11 income tax imposed by the country or pos12 session, or 

13 ‘‘(ii) would be paid if the generally ap14 plicable income tax imposed by the country 

15 or possession were applicable to such dual 

16 capacity taxpayer. 

17 Nothing in this paragraph shall be construed to 

18 imply the proper treatment of any such amount not 

19 in excess of the amount determined under subpara20 graph (B). 

21 ‘‘(2) DUAL CAPACITY TAXPAYER.—For pur22 poses of this subsection, the term ‘dual capacity tax23 payer’ means, with respect to any foreign country or 

24 possession of the United States, a person who— 


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

2 possession, and 

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

4 indirectly a specific economic benefit (as deter5 mined in accordance with regulations) from 

6 such country or possession. 

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

8 For purposes of this subsection— 

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

10 applicable income tax’ means an income tax (or 

11 a series of income taxes) which is generally im12 posed under the laws of a foreign country or 

13 possession on income derived from the conduct 

14 of a trade or business within such country or 

15 possession. 

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

17 include a tax unless it has substantial applica18 tion, by its terms and in practice, to— 

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

20 taxpayers, and 

21 ‘‘(ii) persons who are citizens or resi22 dents of the foreign country or posses23 sion.’’. 

24 (b) EFFECTIVE DATE.— 


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

2 this section shall apply to taxes paid or accrued in 

3 taxable years beginning after the date of the enact4 ment of this Act. 

5 (2) CONTRARY TREATY OBLIGATIONS

6 UPHELD.—The amendments made by this section 

7 shall not apply to the extent contrary to any treaty 

8 obligation of the United States. 

9 SEC. 203. LIMITATION ON SECTION 199 DEDUCTION ATTRIB10 UTABLE TO OIL, NATURAL GAS, OR PRIMARY 

11 PRODUCTS THEREOF. 

12 (a) DENIAL OF DEDUCTION.—Paragraph (4) of sec13 tion 199(c) of the Internal Revenue Code of 1986 is 

14 amended by adding at the end the following new subpara15 graph: 

16 ‘‘(E) SPECIAL RULE FOR CERTAIN OIL

17 AND GAS INCOME.—In the case of any taxpayer 

18 who is a major integrated oil company (as de19 fined in section 167(h)(5)(B)) for the taxable 

20 year, the term ‘domestic production gross re21 ceipts’ shall not include gross receipts from the 

22 production, transportation, or distribution of 

23 oil, natural gas, or any primary product (within 

24 the meaning of subsection (d)(9)) thereof.’’. 


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

2 this section shall apply to taxable years beginning after 

3 December 31, 2013. 

4 SEC. 204. LIMITATION ON DEDUCTION FOR INTANGIBLE 

5 DRILLING AND DEVELOPMENT COSTS. 

6 (a) IN GENERAL.—Section 263(c) of the Internal 

7 Revenue Code of 1986 is amended by adding at the end 

8 the following new sentence: ‘‘This subsection shall not 

9 apply to amounts paid or incurred by a taxpayer in any 

10 taxable year in which such taxpayer is a major integrated 

11 oil company (as defined in section 167(h)(5)(B)).’’. 

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

13 this section shall apply to amounts paid or incurred in tax14 able years beginning after December 31, 2013. 

15 SEC. 205. LIMITATION ON PERCENTAGE DEPLETION AL16 LOWANCE FOR OIL AND GAS WELLS. 

17 (a) IN GENERAL.—Section 613A of the Internal Rev18 enue Code of 1986 is amended by adding at the end the 

19 following new subsection: 

20 ‘‘(f) APPLICATION WITH RESPECT TO MAJOR INTE21 GRATED OIL COMPANIES.—In the case of any taxable year 

22 in which the taxpayer is a major integrated oil company 

23 (as defined in section 167(h)(5)(B)), the allowance for 

24 percentage depletion shall be zero.’’. 


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

2 this section shall apply to taxable years beginning after 

3 December 31, 2013. 

4 SEC. 206. LIMITATION ON DEDUCTION FOR TERTIARY 

5 INJECTANTS. 

6 (a) IN GENERAL.—Section 193 of the Internal Rev7 enue Code of 1986 is amended by adding at the end the 

8 following new subsection: 

9 ‘‘(d) APPLICATION WITH RESPECT TO MAJOR INTE10 GRATED OIL COMPANIES.—This section shall not apply to 

11 amounts paid or incurred by a taxpayer in any taxable 

12 year in which such taxpayer is a major integrated oil com13 pany (as defined in section 167(h)(5)(B)).’’. 

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

15 this section shall apply to amounts paid or incurred in tax16 able years beginning after December 31, 2013. 

Æ 


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