‘‘(i) equipment which uses solar en-
ergy to generate electricity, 
‘‘(ii) fuel cell power plants (as defined 
in section 48(c)(1)(C)), or 
‘‘(iii) systems for the electro-chemical 
storage of electricity (other than lead-acid 
batteries) for use— 
‘‘(I) in electric or hybrid-electric 
motor vehicles, or 
‘‘(II) in connection with electric 
grids. 
‘‘(B) TERMINATION.—Such term shall not 
include any property for any period after De-
cember 31, 2016.’’. 
(3) DENIAL OF DOUBLE BENEFIT.—Subsection 
(e) of section 48C of such Code is amended by add-
ing at the end the following: ‘‘Statutory advanced 
energy property shall not be taken into account in 
determining the qualified investment in any quali-
fying advanced energy project.’’. 
(b) EXTENSION AND MODIFICATION OF THE QUALI-
FYING ADVANCED ENERGY PROJECT PROGRAM.— 
(1) ADDITIONAL LIMITATION AMOUNT TO BE 
COMPETITIVELY ALLOCATED BY SECRETARY.—Sub-
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paragraph (B) of section 48C(d)(1) of such Code is 
amended to read as follows: 
‘‘(B) LIMITATION.—The total amount of 
qualified investments which may be designated 
under such program shall not exceed the 
amount which will result in the total amount of 
credits allowed under such program being equal 
to the sum of the following amounts: 
‘‘(i) 2009 
LIMITATION
AMOUNT.— 
$2,300,000,000. 
‘‘(ii) 2012 LIMITATION
AMOUNT.— 
$3,000,000,000.’’. 
(2) MANUFACTURING OF PROPERTY USED TO 
PRODUCE COMPOSITE UTILITY POLES.—Clause (i) of 
section 48C(c)(1)(A) of such Code is amended by 
striking ‘‘or’’ at the end of subclause (VI), by redes-
ignating subclause (VII) as subclause (VIII), and by 
inserting after subclause (VI) the following new sub-
clause: 
‘‘(VII) utility poles or supports 
made from composite materials which 
are comprised of at least 15 percent 
recycled materials and are fully recy-
clable,’’. 
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(3) PREFERENCE IN SELECTION CRITERIA FOR 
MANUFACTURING.—Paragraph (3) of section 48C(d) 
of such Code is amended by striking ‘‘and’’ at the 
end of subparagraph (A), by striking the period at 
the end of subparagraph (B) and inserting ‘‘, and’’, 
and by adding at the end the following new subpara-
graph: 
‘‘(C) shall give the lowest priority to 
projects which merely assemble components.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Paragraph (3) of section 48C(b) of such 
Code is amended to read as follows: 
‘‘(3) LIMITATION.—The amount which is treat-
ed as a qualified investment for all taxable years 
with respect to any qualifying advanced manufac-
turing project shall not exceed the amount des-
ignated by the Secretary under subsection (d).’’. 
(2) Subparagraph (A) of section 48C(c)(2) of 
such Code is amended by inserting ‘‘in the case of 
a qualifying advanced energy project,’’ before ‘‘which 
is necessary’’. 
(3) Subparagraph (A) of section 48C(d)(2) of 
such Code is amended— 
(A) by striking ‘‘during the 2-year period’’ 
and inserting ‘‘during the— 
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‘‘(i) in the case of an allocation from 
the limitation described in paragraph 
(1)(B)(i), the 2-year period’’, 
(B) by striking the period at the end and 
inserting ‘‘, or’’, and 
(C) by adding at the end the following new 
clause: 
‘‘(ii) in the case of an allocation from 
the limitation described in paragraph 
(1)(B)(ii), the 1-year period beginning on 
the date of the enactment of this clause.’’. 
(4) Paragraph (4) of section 48C(d) of such 
Code is amended— 
(A) by striking all that precedes subpara-
graph (A) and inserting the following: 
‘‘(4) PERIODIC
REVIEW
AND
REDISTRIBU-
TION.—At such times as the Secretary determines 
appropriate—’’, and 
(B) by striking ‘‘Not later than 4 years 
after the date of the enactment of this section, 
the’’ in subparagraph (A) and inserting ‘‘The’’. 
(5) Clause (v) of section 49(a)(1)(C) of such 
Code is amended by inserting ‘‘which is statutory 
advanced energy property (as defined in section 
48C(c)(3)) or’’ after ‘‘the basis of any property’’. 
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(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to periods after the date of the 
enactment of this Act, under rules similar to the rules of 
section 48(m) of the Internal Revenue Code of 1986 (as 
in effect on the day before the date of the enactment of 
the Revenue Reconciliation Act of 1990). 
SEC. 3. MODIFICATIONS OF FOREIGN TAX CREDIT RULES 
APPLICABLE TO MAJOR INTEGRATED OIL 
COMPANIES WHICH ARE DUAL CAPACITY 
TAXPAYERS. 
(a) IN GENERAL.—Section 901 of the Internal Rev-
enue Code of 1986 is amended by redesignating subsection 
(n) as subsection (o) and by inserting after subsection (m) 
the following new subsection: 
‘‘(n) SPECIAL RULES RELATING TO MAJOR INTE-
GRATED OIL COMPANIES WHICH ARE DUAL CAPACITY 
TAXPAYERS.— 
‘‘(1) GENERAL
RULE.—Notwithstanding any 
other provision of this chapter, any amount paid or 
accrued by a dual capacity taxpayer which is a 
major integrated oil company (as defined in section 
167(h)(5)(B)) to a foreign country or possession of 
the United States for any period shall not be consid-
ered a tax— 
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‘‘(A) if, for such period, the foreign coun-
try or possession does not impose a generally 
applicable income tax, or 
‘‘(B) to the extent such amount exceeds 
the amount (determined in accordance with reg-
ulations) which— 
‘‘(i) is paid by such dual capacity tax-
payer pursuant to the generally applicable 
income tax imposed by the country or pos-
session, or 
‘‘(ii) would be paid if the generally ap-
plicable income tax imposed by the country 
or possession were applicable to such dual 
capacity taxpayer. 
Nothing in this paragraph shall be construed to 
imply the proper treatment of any such amount not 
in excess of the amount determined under subpara-
graph (B). 
‘‘(2) DUAL
CAPACITY
TAXPAYER.—For pur-
poses of this subsection, the term ‘dual capacity tax-
payer’ means, with respect to any foreign country or 
possession of the United States, a person who— 
‘‘(A) is subject to a levy of such country or 
possession, and 
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