102
‘‘(i) in the case of qualified crude oil 
production, the reference price determined 
under section 29(d)(2)(C), and 
‘‘(ii) in the case of qualified natural 
gas production, the Secretary’s estimate of 
the annual average wellhead price per 1,000 
cubic feet for all domestic natural gas. 
‘‘(c) QUALIFIED CRUDE OIL AND NATURAL GAS PRO-
DUCTION.—For purposes of this section—
‘‘(1) IN GENERAL.—The terms ‘qualified crude 
oil production’ and ‘qualified natural gas production’ 
mean domestic crude oil or natural gas which is pro-
duced from a qualified marginal well. 
‘‘(2) LIMITATION ON AMOUNT OF PRODUCTION 
WHICH MAY QUALIFY.—
‘‘(A) IN GENERAL.—Crude oil or natural 
gas produced during any taxable year from any 
well shall not be treated as qualified crude oil 
production or qualified natural gas production 
to the extent production from the well during the 
taxable year exceeds 1,095 barrels or barrel 
equivalents. 
‘‘(B) PROPORTIONATE REDUCTIONS.—
‘‘(i) SHORT TAXABLE YEARS.—In the 
case of a short taxable year, the limitations
103
under this paragraph shall be proportion-
ately reduced to reflect the ratio which the 
number of days in such taxable year bears 
to 365. 
‘‘(ii) WELLS NOT IN PRODUCTION EN-
TIRE YEAR.—In the case of a well which is 
not capable of production during each day 
of a taxable year, the limitations under this 
paragraph applicable to the well shall be 
proportionately reduced to reflect the ratio 
which the number of days of production 
bears to the total number of days in the tax-
able year. 
‘‘(3) DEFINITIONS.—
‘‘(A) QUALIFIED
MARGINAL
WELL.—The 
term ‘qualified marginal well’ means a domestic 
well—
‘‘(i) the production from which during 
the taxable year is treated as marginal pro-
duction under section 613A(c)(6), or 
‘‘(ii) which, during the taxable year—
‘‘(I) has average daily production 
of not more than 25 barrel equivalents, 
and
104
‘‘(II) produces water at a rate not 
less than 95 percent of total well efflu-
ent. 
‘‘(B) CRUDE OIL, ETC.—The terms ‘crude 
oil’, ‘natural gas’, ‘domestic’, and ‘barrel’ have 
the meanings given such terms by section 
613A(e). 
‘‘(C) BARREL EQUIVALENT.—The term ‘bar-
rel equivalent’ means, with respect to natural 
gas, a conversion ratio of 6,000 cubic feet of nat-
ural gas to 1 barrel of crude oil. 
‘‘(d) OTHER RULES.—
‘‘(1) PRODUCTION ATTRIBUTABLE TO THE TAX-
PAYER.—In the case of a qualified marginal well in 
which there is more than one owner of operating in-
terests in the well and the crude oil or natural gas 
production exceeds the limitation under subsection 
(c)(2), qualifying crude oil production or qualifying 
natural gas production attributable to the taxpayer 
shall be determined on the basis of the ratio which 
taxpayer’s revenue interest in the production bears to 
the aggregate of the revenue interests of all operating 
interest owners in the production. 
‘‘(2) OPERATING
INTEREST
REQUIRED.—Any 
credit under this section may be claimed only on pro-
105
duction which is attributable to the holder of an oper-
ating interest. 
‘‘(3) 
PRODUCTION
FROM
NONCONVENTIONAL 
SOURCES EXCLUDED.—In the case of production from 
a qualified marginal well which is eligible for the 
credit allowed under section 29 for the taxable year, 
no credit shall be allowable under this section unless 
the taxpayer elects not to claim the credit under sec-
tion 29 with respect to the well.’’. 
(b) CREDIT TREATED AS BUSINESS CREDIT.—Section 
38(b) is amended by striking ‘‘plus’’ at the end of para-
graph (16), by striking the period at the end of paragraph 
(17) and inserting ‘‘, plus’’, and by adding at the end the 
following: 
‘‘(18) the marginal oil and gas well production 
credit determined under section 45I(a).’’. 
(c) CARRYBACK.—Subsection (a) of section 39 (relat-
ing to carryback and carryforward of unused credits gen-
erally) is amended by adding at the end the following: 
‘‘(3) 10-YEAR
CARRYBACK
FOR
MARGINAL
OIL 
AND GAS WELL PRODUCTION CREDIT.—In the case of 
the marginal oil and gas well production credit—
‘‘(A) this section shall be applied separately 
from the business credit (other than the marginal 
oil and gas well production credit),
106
‘‘(B) paragraph (1) shall be applied by sub-
stituting ‘10 taxable years’ for ‘1 taxable years’ 
in subparagraph (A) thereof, and 
‘‘(C) paragraph (2) shall be applied—
‘‘(i) by substituting ‘31 taxable years’ 
for ‘21 taxable years’ in subparagraph (A) 
thereof, and 
‘‘(ii) by substituting ‘30 taxable years’ 
for ‘20 taxable years’ in subparagraph (A) 
thereof.’’. 
(d) COORDINATION WITH SECTION 29.—Section 29(a) 
is amended by striking ‘‘There’’ and inserting ‘‘At the elec-
tion of the taxpayer, there’’. 
(e) CLERICAL AMENDMENT.—The table of sections for 
subpart D of part IV of subchapter A of chapter 1 is amend-
ed by adding at the end the following:
‘‘Sec. 45I. Credit for producing oil and gas from marginal wells.’’.
(f) EFFECTIVE DATE.—The amendments made by this 
section shall apply to production in taxable years beginning 
after December 31, 2003.
108
SEC. 303. AMORTIZATION OF DELAY RENTAL PAYMENTS. 
(a) IN GENERAL.—Section 167 (relating to deprecia-
tion) is amended by redesignating subsection (h) as sub-
section (i) and by inserting after subsection (g) the fol-
lowing new subsection: 
‘‘(h) AMORTIZATION OF DELAY RENTAL PAYMENTS 
FOR DOMESTIC OIL AND GAS WELLS.—
‘‘(1) IN GENERAL.—Any delay rental payment 
paid or incurred in connection with the development 
of oil or gas wells within the United States (as de-
fined in section 638) shall be allowed as a deduction 
ratably over the 24-month period beginning on the 
date that such payment was paid or incurred. 
‘‘(2) HALF-YEAR CONVENTION.—For purposes of 
paragraph (1), any payment paid or incurred during 
the taxable year shall be treated as paid or incurred 
on the mid-point of such taxable year. 
‘‘(3) EXCLUSIVE METHOD.—Except as provided 
in this subsection, no depreciation or amortization 
deduction shall be allowed with respect to such pay-
ments. 
‘‘(4) TREATMENT UPON ABANDONMENT.—If any 
property to which a delay rental payment relates is 
retired or abandoned during the 24-month period de-
scribed in paragraph (1), no deduction shall be al-
lowed on account of such retirement or abandonment
109
and the amortization deduction under this subsection 
shall continue with respect to such payment. 
‘‘(5) DELAY RENTAL PAYMENTS.—For purposes 
of this subsection, the term ‘delay rental payment’ 
means an amount paid for the privilege of deferring 
development of an oil or gas well under an oil or gas 
lease.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to amounts paid or incurred in taxable 
years beginning after December 31, 2003. 
SEC. 304. AMORTIZATION OF GEOLOGICAL AND GEO-
PHYSICAL EXPENDITURES. 
(a) IN GENERAL.—Section 167 (relating to deprecia-
tion) is amended by redesignating subsection (i) as sub-
section (j) and by inserting after subsection (h) the fol-
lowing new subsection: 
‘‘(i) AMORTIZATION
OF
GEOLOGICAL
AND
GEO-
PHYSICAL EXPENDITURES.—
‘‘(1) IN
GENERAL.—Any geological and geo-
physical expenses paid or incurred in connection with 
the exploration for, or development of, oil or gas with-
in the United States (as defined in section 638) shall 
be allowed as a deduction ratably over the 24-month 
period beginning on the date that such expense was 
paid or incurred.
110
‘‘(2) SPECIAL RULES.—For purposes of this sub-
section, rules similar to the rules of paragraphs (2), 
(3), and (4) of subsection (h) shall apply.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to costs paid or incurred in taxable 
years beginning after December 31, 2003. 
SEC. 305. EXTENSION AND MODIFICATION OF CREDIT FOR 
PRODUCING 
FUEL 
FROM 
A 
NONCONVEN-
TIONAL SOURCE. 
(a) IN GENERAL.—Section 29 is amended by adding 
at the end the following new subsection: 
‘‘(h) EXTENSION FOR OTHER FACILITIES.—
‘‘(1) EXTENSION FOR OIL AND CERTAIN GAS.—In 
the case of a well for producing qualified fuels de-
scribed in subparagraph (A) or (B)(i) of subsection 
(c)(1)—
‘‘(A) APPLICATION
OF
CREDIT
FOR
NEW 
WELLS.—Notwithstanding subsection (f), this 
section shall apply with respect to such fuels—
‘‘(i) which are produced from a well 
drilled after the date of the enactment of 
this subsection and before January 1, 2007, 
and 
‘‘(ii) which are sold not later than the 
close of the 4-year period beginning on the
111
date that such well is drilled, or, if earlier, 
January 1, 2010. 
‘‘(B) EXTENSION
OF
CREDIT
FOR
OLD 
WELLS.—Subsection (f)(2) shall be applied by 
substituting ‘2007’ for ‘2003’ with respect to 
wells described in subsection (f)(1)(A) with re-
spect to such fuels. 
‘‘(2) EXTENSION
FOR
FACILITIES
PRODUCING 
QUALIFIED FUEL FROM LANDFILL GAS.—
‘‘(A) IN GENERAL.—In the case of a facility 
for producing qualified fuel from landfill gas 
which was placed in service after June 30, 1998, 
and before January 1, 2007, this section shall 
apply to fuel produced at such facility during 
the 5-year period beginning on the later of—
‘‘(i) the date such facility was placed 
in service, or 
‘‘(ii) the date of the enactment of this 
subsection. 
‘‘(B) REDUCTION OF CREDIT FOR CERTAIN 
LANDFILL FACILITIES.—In the case of a facility 
to which paragraph (1) applies and which is lo-
cated at a landfill which is required pursuant to 
section 60.751(b)(2) or section 60.33c of title 40, 
Code of Federal Regulations (as in effect on
112
April 3, 2003) to install and operate a collection 
and control system which captures gas generated 
within the landfill, subsection (a)(1) shall be ap-
plied to gas so captured by substituting ‘$2’ for 
‘$3’ for the taxable year during which such sys-
tem is required to be installed and operated. 
‘‘(3) SPECIAL
RULES.—In determining the 
amount of credit allowable under this section solely 
by reason of this subsection—
‘‘(A) DAILY LIMIT.—The amount of quali-
fied fuels sold during any taxable year which 
may be taken into account by reason of this sub-
section with respect to any project shall not ex-
ceed an average barrel-of-oil equivalent of 
200,000 cubic feet of natural gas per day. Days 
before the date the project is placed in service 
shall not be taken into account in determining 
such average. 
‘‘(B) EXTENSION
PERIOD
TO
COMMENCE 
WITH
UNADJUSTED
CREDIT
AMOUNT.—In the 
case of fuels sold during 2003, the dollar amount 
applicable under subsection (a)(1) shall be $3 
(without regard to subsection (b)(2)). In the case 
of fuels sold after 2003, subparagraph (B) of sub-
113
section (d)(2) shall be applied by substituting 
‘2003’ for ‘1979’.’’. 
(b) TREATMENT AS BUSINESS CREDIT.—
(1) CREDIT MOVED TO SUBPART RELATING TO 
BUSINESS RELATED CREDITS.—The Internal Revenue 
Code of 1986 is amended by redesignating section 29 
as section 45J and by moving section 45J (as so re-
designated) from subpart B of part IV of subchapter 
A of chapter 1 to the end of subpart D of part IV of 
subchapter A of chapter 1. 
(2) CREDIT TREATED AS BUSINESS CREDIT.—
Section 38(b) is amended by striking ‘‘plus’’ at the 
end of paragraph (17), by striking the period at the 
end of paragraph (18) and inserting ‘‘, plus’’, and by 
adding at the end the following: 
‘‘(19) the nonconventional source production 
credit determined under section 45J(a).’’. 
(3) CONFORMING AMENDMENTS.—
(A) Section 30(b)(2)(A), as redesignated by 
section 110(a), is amended by striking ‘‘sections 
27 and 29’’ and inserting ‘‘section 27’’. 
(B) Section 30B(d), as added by section 
111, is amended by striking ‘‘, 29,’’. 
(C) Section 39(d) is amended by adding at 
the end the following new paragraph:
114
‘‘(13) NO
CARRYBACK
FOR
NONCONVENTIONAL 
SOURCE PRODUCTION CREDIT.—No portion of the un-
used business credit for any taxable year which is at-
tributable to the credit under section 45J may be car-
ried back to a taxable year ending before April 1, 
2003.’’. 
(D) Sections 43(b)(2), 45I(b)(2)(C) (as 
added by section 301), and 613A(c)(6)(C) are 
each amended by striking ‘‘section 29(d)(2)(C)’’ 
and inserting ‘‘section 45J(d)(2)(C)’’. 
(E) Paragraph (9) of section 45(c), as 
added by section 102(c), is amended by striking 
‘‘section 29’’ and inserting ‘‘section 45J’’ and by 
striking ‘‘SECTION 29’’ in the heading of such 
paragraph and inserting ‘‘SECTION 45J’’. 
(F) Section 45I(d)(3), as added by section 
301, is amended by striking ‘‘section 29’’ each 
place it appears and inserting ‘‘section 45J’’. 
(G) Section 45J(a), as amended by section 
301(d) and redesignated by paragraph (1), is 
amended by striking ‘‘At the election of the tax-
payer, there shall be allowed as a credit against 
the tax imposed by this chapter for the taxable 
year’’ and inserting ‘‘For purposes of section 38, 
if the taxpayer elects to have this section apply,
115
the nonconventional source production credit de-
termined under this section for the taxable year 
is’’. 
(H) Section 45J(b), as so redesignated, is 
amended by striking paragraph (6). 
(I) Section 53(d)(1)(B)(iii) is amended by 
striking ‘‘under section 29’’ and all that follows 
through ‘‘or not allowed’’. 
(J) Section 55(c)(2) is amended by striking 
‘‘29(b)(6),’’. 
(K) Subsection (a) of section 772 is amend-
ed by inserting ‘‘and’’ at the end of paragraph 
(9), by striking paragraph (10), and by redesig-
nating paragraph (11) as paragraph (10). 
(L) Paragraph (5) of section 772(d) is 
amended by striking ‘‘the foreign tax credit, and 
the credit allowable under section 29’’ and in-
serting ‘‘and the foreign tax credit’’. 
(M) The table of sections for subpart B of 
part IV of subchapter A of chapter 1 is amended 
by striking the item relating to section 29. 
(N) The table of sections for subpart D of 
part IV of subchapter A of chapter 1 is amended 
by inserting after the item relating to section 45I 
the following new item:
116
‘‘Sec. 45J. Credit for producing fuel from a nonconventional 
source.’’.
(c) EFFECTIVE DATES.—
(1) IN GENERAL.—The amendment made by sub-
section (a) shall apply to fuel sold after March 31, 
2003, in taxable years ending after such date. 
(2) TREATMENT
AS
BUSINESS
CREDIT.—The 
amendments made by subsection (b) shall apply to 
taxable years ending after March 31, 2003. 
SEC. 306. BUSINESS RELATED ENERGY CREDITS ALLOWED 
AGAINST REGULAR AND MINIMUM TAX. 
(a) IN GENERAL.—Subsection (c) of section 38 (relat-
ing to limitation based on amount of tax) is amended by 
redesignating paragraph (4) as paragraph (5) and by in-
serting after paragraph (3) the following new paragraph: 
‘‘(4) SPECIAL
RULES
FOR
SPECIFIED
ENERGY 
CREDITS.—
‘‘(A) IN GENERAL.—In the case of specified 
energy credits—
‘‘(i) this section and section 39 shall be 
applied separately with respect to such 
credits, and 
‘‘(ii) in applying paragraph (1) to 
such credits—
‘‘(I) the tentative minimum tax 
shall be treated as being zero, and
117
‘‘(II) the limitation under para-
graph (1) (as modified by subclause 
(I)) shall be reduced by the credit al-
lowed under subsection (a) for the tax-
able year (other than the specified en-
ergy credits). 
‘‘(B) SPECIFIED
ENERGY
CREDITS.—For 
purposes of this subsection, the term ‘specified 
energy credits’ means the credits determined 
under sections 45G, 45H, and 45I. 
‘‘(C) SPECIAL RULE FOR QUALIFIED WIND 
FACILITIES.—For purposes of this subsection, the 
term ‘specified energy credits’ shall include the 
credit determined under section 45 to the extent 
that such credit is attributable to electricity pro-
duced—
‘‘(i) at a facility using wind to 
produce electricity which is originally 
placed in service after the date of the enact-
ment of this paragraph, and 
‘‘(ii) during the 4-year period begin-
ning on the date that such facility was 
originally placed in service.’’. 
(b) 
CONFORMING
AMENDMENTS.—Paragraphs 
(2)(A)(ii)(II) and (3)(A)(ii)(II) of section 38(c) are each
118
amended by inserting ‘‘or the specified energy credits’’ after 
‘‘employee credit’’. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years ending after the date 
of the enactment of this Act. 
SEC. 307. TEMPORARY REPEAL OF ALTERNATIVE MINIMUM 
TAX PREFERENCE FOR INTANGIBLE DRILL-
ING COSTS. 
(a) IN GENERAL.—Clause (ii) of section 57(a)(2)(E) 
is amended by adding at the end the following new sentence: 
‘‘The preceding sentence shall not apply to taxable years 
beginning after December 31, 2003, and before January 1, 
2006.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2003. 
SEC. 308. ALLOWANCE OF ENHANCED RECOVERY CREDIT 
AGAINST THE ALTERNATIVE MINIMUM TAX. 
(a) IN
GENERAL.—Subparagraph (B) of section 
38(c)(4), as amended by section 306, is amended by adding 
at the end the following new sentence: ‘‘For taxable years 
beginning after December 31, 2003, and before January 1, 
2006, such term includes the credit determined under sec-
tion 43.’’.
119
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2003. 
TITLE IV—CORPORATE 
EXPATRIATION
SEC. 401. TAX TREATMENT OF CORPORATE EXPATRIATION. 
(a) IN GENERAL.—Subchapter C of chapter 80 (relat-
ing to provisions affecting more than one subtitle) is 
amended by adding at the end the following new section: 
‘‘SEC. 7874. TAX TREATMENT OF CORPORATE EXPATRIA-
TION. 
‘‘(a) INVERTED CORPORATIONS TREATED AS DOMES-
TIC CORPORATIONS.—
‘‘(1) IN GENERAL.—If a foreign incorporated en-
tity is treated as an inverted domestic corporation, 
then, notwithstanding section 7701(a)(4), such entity 
shall be treated for purposes of this title as a domestic 
corporation. 
‘‘(2) INVERTED
DOMESTIC
CORPORATION.—For 
purposes of this section, a foreign incorporated entity 
shall be treated as an inverted domestic corporation 
if, pursuant to a plan (or a series of related trans-
actions)—
‘‘(A) the entity completes after March 4, 
2003, the direct or indirect acquisition of sub-
120
stantially all of the properties held directly or 
indirectly by a domestic corporation or substan-
tially all of the properties constituting a trade or 
business of a domestic partnership, 
‘‘(B) after the acquisition at least 80 per-
cent of the stock (by vote or value) of the entity 
is held—
‘‘(i) in the case of an acquisition with 
respect to a domestic corporation, by former 
shareholders of the domestic corporation by 
reason of holding stock in the domestic cor-
poration, or 
‘‘(ii) in the case of an acquisition with 
respect to a domestic partnership, by former 
partners of the domestic partnership by rea-
son of holding a capital or profits interest 
in the domestic partnership, and 
‘‘(C) the expanded affiliated group which 
after the acquisition includes the entity does not 
have substantial business activities in the foreign 
country in which or under the law of which the 
entity is created or organized when compared to 
the total business activities of such expanded af-
filiated group.
121
‘‘(3) TERMINATION.—This subsection shall not 
apply to any acquisition completed after December 
31, 2004. 
‘‘(b) DEFINITIONS AND SPECIAL RULES.—For pur-
poses of this section—
‘‘(1) FOREIGN
INCORPORATED
ENTITY.—The 
term ‘foreign incorporated entity’ means any entity 
which is, or but for subsection (a) would be, treated 
as a foreign corporation for purposes of this title. 
‘‘(2) EXPANDED AFFILIATED GROUP.—The term 
‘expanded affiliated group’ means an affiliated group 
as defined in section 1504(a) but without regard to 
paragraphs (2), (3), and (4) of section 1504(b), except 
that section 1504(a) shall be applied by substituting 
‘more than 50 percent’ for ‘at least 80 percent’ each 
place it appears. 
‘‘(3) CERTAIN
STOCK
DISREGARDED.—There 
shall not be taken into account in determining owner-
ship under subsection (a)(3)(B)—
‘‘(A) stock held by members of the expanded 
affiliated group which includes the foreign incor-
porated entity, or 
‘‘(B) stock of such foreign incorporated enti-
ty which is sold in a public offering related to 
the acquisition described in subsection (a)(3)(A).
122
‘‘(4) PLAN DEEMED IN CERTAIN CASES.—If a 
foreign incorporated entity acquires directly or indi-
rectly substantially all of the properties of a domestic 
corporation or partnership during the 4-year period 
beginning on the date which is 2 years before the 
ownership requirements of subsection (a)(3)(B) are 
met, such actions shall be treated as pursuant to a 
plan. 
‘‘(5) CERTAIN TRANSFERS DISREGARDED.—The 
transfer of properties or liabilities (including by con-
tribution or distribution) shall be disregarded if such 
transfers are part of a plan a principal purpose of 
which is to avoid the purposes of this section. 
‘‘(6) SPECIAL
RULE
FOR
RELATED
PARTNER-
SHIPS.—For 
purposes 
of 
applying 
subsection 
(a)(3)(B) to the acquisition of a domestic partnership, 
except as provided in regulations, all partnerships 
which are under common control (within the meaning 
of section 482) shall be treated as 1 partnership. 
‘‘(7) REGULATIONS.—The Secretary shall pre-
scribe such regulations as may be appropriate to de-
termine whether a corporation is an inverted domestic 
corporation, including regulations—
123
‘‘(A) to treat warrants, options, contracts to 
acquire stock, convertible debt interests, and 
other similar interests as stock, and 
‘‘(B) to treat stock as not stock. 
‘‘(c) SPECIAL RULE FOR TREATIES.—Nothing in sec-
tion 894 or 7852(d) or in any other provision of law shall 
be construed as permitting an exemption, by reason of any 
treaty obligation of the United States heretofore or hereafter 
entered into, from the provisions of this section. 
‘‘(d) REGULATIONS.—The Secretary shall provide such 
regulations as are necessary to carry out this section, in-
cluding regulations providing for such adjustments to the 
application of this section as are necessary to prevent the 
avoidance of the purposes of this section, including the 
avoidance of such purposes through—
‘‘(1) the use of related persons, pass-through or 
other noncorporate entities, or other intermediaries, 
or 
‘‘(2) transactions designed to have persons cease 
to be (or not become) members of expanded affiliated 
groups or related persons.’’. 
(b) CONFORMING AMENDMENT.—The table of sections 
for subchapter C of chapter 80 is amended by adding at 
the end the following new item:
‘‘Sec. 7874. Tax treatment of corporate expatriation.’’.
124
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years ending after March 4, 
2003.
SEC. 402. EXPRESSING THE SENSE OF THE CONGRESS THAT 
TAX REFORM IS NEEDED TO ADDRESS THE 
ISSUE OF CORPORATE EXPATRIATION. 
(a) FINDINGS.—The Congress finds that—
(1) the tax laws of the United States are overly 
complex; 
(2) the tax laws of the United States are among 
the most burdensome and uncompetitive in the world; 
(3) the tax laws of the United States make it dif-
ficult for domestically-owned United States companies 
to compete abroad and in the United States; 
(4) a domestically-owned corporation is dis-
advantaged compared to a United States subsidiary 
of a foreign-owned corporation; and 
(5) international competitiveness is forcing 
many United States corporations to make a choice 
they do not want to make—go out of business, sell the 
business to a foreign competitor, or become a sub-
sidiary of a foreign corporation (i.e., engage in an in-
version transaction). 
(b) SENSE OF CONGRESS.—It is the sense of Congress 
that passage of legislation to fix the underlying problems
125
with our tax laws is essential and should occur as soon as 
possible, so United States corporations will not face the cur-
rent pressures to engage in inversion transactions.
Union Calendar No. 41
108TH CONGRESS 
1ST SESSION 
H. R. 1531
[Report No. 108–67] 
A BILL 
To amend the Internal Revenue Code of 1986 to 
enhance energy conservation and to provide for 
reliability and diversity in the energy supply for 
the American people, and for other purposes. 
APRIL 9, 2003
Reported with an amendment, committed to the Com-
mittee of the Whole House on the State of the Union, 
and ordered to be printed