I 
114TH CONGRESS 
1ST SESSION H. R. 2883 
To amend the Internal Revenue Code of 1986 to extend the publicly traded 
partnership ownership structure to energy power generation projects and 
transportation fuels, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
JUNE 24, 2015 
Mr. POE of Texas (for himself, Mr. THOMPSON of California, Mr. AMODEI, 
Mr. WELCH, Mr. GOSAR, Mr. BLUMENAUER, Mr. COFFMAN, and Mr. 
MCNERNEY) introduced the following bill; which was referred to the Com-
mittee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to extend 
the publicly traded partnership ownership structure to 
energy power generation projects and transportation 
fuels, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Master Limited Part-
nerships Parity Act’’. 
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SEC. 2. EXTENSION OF PUBLICLY TRADED PARTNERSHIP 
OWNERSHIP STRUCTURE TO ENERGY POWER 
GENERATION PROJECTS, TRANSPORTATION 
FUELS, AND RELATED ENERGY ACTIVITIES. 
(a) IN GENERAL.—Subparagraph (E) of section 
7704(d)(1) of the Internal Revenue Code of 1986 is 
amended— 
(1) by striking ‘‘income and gains derived from 
the exploration’’ and inserting ‘‘income and gains 
derived from the following: 
‘‘(i) 
MINERALS, 
NATURAL
RE-
SOURCES, ETC.—The exploration’’, 
(2) 
by 
inserting 
‘‘or’’ 
before 
‘‘industrial 
source’’, 
(3) by inserting a period after ‘‘carbon diox-
ide’’, and 
(4) by striking ‘‘, or the transportation or stor-
age’’ and all that follows and inserting the following: 
‘‘(ii) RENEWABLE ENERGY.—The gen-
eration of electric power (including the 
leasing of tangible personal property used 
for such generation) exclusively utilizing 
any resource described in section 45(c)(1) 
or energy property described in section 48 
(determined without regard to any termi-
nation date), or in the case of a facility de-
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scribed in paragraph (3) or (7) of section 
45(d) (determined without regard to any 
placed in service date or date by which 
construction of the facility is required to 
begin), the accepting or processing of such 
resource. 
‘‘(iii) 
ELECTRICITY
STORAGE
DE-
VICES.—The receipt and sale of electric 
power that has been stored in a device di-
rectly connected to the grid. 
‘‘(iv) COMBINED HEAT AND POWER.— 
The generation, storage, or distribution of 
thermal energy exclusively utilizing prop-
erty described in section 48(c)(3) (deter-
mined without regard to subparagraphs 
(B) and (D) thereof and without regard to 
any placed in service date). 
‘‘(v) 
RENEWABLE
THERMAL
EN-
ERGY.—The generation, storage, or dis-
tribution of thermal energy exclusively 
using any resource described in section 
45(c)(1) or energy property described in 
clause (i) or (iii) of section 48(a)(3)(A). 
‘‘(vi) WASTE HEAT TO POWER.—The 
use of recoverable waste energy, as defined 
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in section 371(5) of the Energy Policy and 
Conservation Act (42 U.S.C. 6341(5)) (as 
in effect on the date of the enactment of 
the Master Limited Partnerships Parity 
Act). 
‘‘(vii) 
RENEWABLE
FUEL
INFRA-
STRUCTURE.—The storage or transpor-
tation of any fuel described in subsection 
(b), (c), (d), or (e) of section 6426. 
‘‘(viii) RENEWABLE FUELS.—The pro-
duction, storage, or transportation of any 
renewable 
fuel 
described 
in 
section 
211(o)(1)(J) of the Clean Air Act (42 
U.S.C. 7545(o)(1)(J)) (as in effect on the 
date of the enactment of the Master Lim-
ited Partnerships Parity Act) or section 
40A(d)(1). 
‘‘(ix) RENEWABLE CHEMICALS.—The 
production, storage, or transportation of 
any qualifying renewable chemical (as de-
fined in paragraph (6)). 
‘‘(x) 
ENERGY
EFFICIENT
BUILD-
INGS.—The audit and installation through 
contract or other agreement of any energy 
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efficient building property described in sec-
tion 179D(c)(1). 
‘‘(xi) GASIFICATION
WITH
SEQUES-
TRATION.—The production of any product 
or the generation of electric power from a 
project that meets the requirements of sub-
paragraphs 
(A) 
and 
(B) 
of 
section 
48B(c)(1) and that separates and seques-
ters in secure geological storage (as deter-
mined under section 45Q(d)(2)) at least 75 
percent of such project’s total qualified 
carbon dioxide (as defined in section 
45Q(b)). 
‘‘(xii) CARBON CAPTURE AND SEQUES-
TRATION.— 
‘‘(I) POWER GENERATION FACILI-
TIES.—The generation or storage of 
electric power (including associated 
income from the sale or marketing of 
energy, capacity, resource adequacy, 
and ancillary services) produced from 
any power generation facility which is, 
or from any power generation unit 
within, a qualified facility described in 
section 45Q(c) which— 
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