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. CAR-
SON, Mr. CLEAVER, Mr. COHEN, Mr. ESPAILLAT, Mr. FROST, Mr. ROB-
ERT 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. RA-
MIREZ, Mr. RASKIN, Ms. SCHAKOWSKY, Mr. SCHIFF, Mr. TAKANO, Ms. 
TLAIB, Mr. TORRES of New York, and Mrs. WATSON COLEMAN) intro-
duced 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. 
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 ‘‘End Polluter Welfare 
Act of 2024’’. 
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SEC. 2. TABLE OF CONTENTS. 
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 opera-
tors. 
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 Devel-
opment Finance Corporation or the Export-Import Bank of the 
United States for financing projects, transactions, or other ac-
tivities that support fossil fuel. 
Sec. 115. Transportation funds for grants, loans, loan guarantees, and other di-
rect 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 ex-
penditures. 
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 in-
dustry 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 Conti-
nental Shelf in the Gulf of Mexico. 
Sec. 213. Repeal of corporate income tax exemption for publicly traded partner-
ships 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 re-
fined 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. 
TITLE I—ELIMINATION OF 
FOSSIL FUEL SUBSIDIES 
SEC. 101. DEFINITION OF FOSSIL FUEL. 
In this Act, the term ‘‘fossil fuel’’ means coal, petro-
leum, natural gas, or any derivative of coal, petroleum, 
or natural gas that is used for fuel. 
SEC. 102. ROYALTY RELIEF. 
(a) IN GENERAL.— 
(1) OUTER CONTINENTAL SHELF LANDS ACT.— 
Section 8(a)(3) of the Outer Continental Shelf 
Lands Act (43 U.S.C. 1337(a)(3)) is amended— 
(A) by striking subparagraph (B); and 
(B) by redesignating subparagraph (C) as 
subparagraph (B). 
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(2) ENERGY POLICY ACT OF 2005.— 
(A) INCENTIVES FOR NATURAL GAS PRO-
DUCTION FROM DEEP WELLS IN THE SHALLOW 
WATERS
OF
THE
GULF
OF
MEXICO.—Section 
344 of the Energy Policy Act of 2005 (42 
U.S.C. 15904) is repealed. 
(B) DEEP WATER PRODUCTION.—Section 
345 of the Energy Policy Act of 2005 (42 
U.S.C. 15905) is repealed. 
(3) CLERICAL AMENDMENT.—The table of con-
tents in section 1(b) of the Energy Policy Act of 
2005 (Public Law 109–58; 119 Stat. 596) is amend-
ed by striking the items relating to sections 344 and 
345. 
(b) FUTURE
PROVISIONS.—Notwithstanding any 
other provision of law, royalty relief shall not be permitted 
under a lease issued under section 8 of the Outer Conti-
nental Shelf Lands Act (43 U.S.C. 1337). 
SEC. 103. ROYALTIES UNDER MINERAL LEASING ACT. 
(a) COAL LEASES.—Section 7(a) of the Mineral 
Leasing Act (30 U.S.C. 207(a)) is amended in the fourth 
sentence by striking ‘‘121⁄2 per centum’’ and inserting 
‘‘183⁄4 percent’’. 
(b) LEASES ON LAND ON WHICH OIL OR NATURAL 
GAS IS DISCOVERED.—Section 14 of the Mineral Leasing 
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Act (30 U.S.C. 223) is amended in the fourth sentence 
by striking ‘‘121⁄2 per centum’’ and inserting ‘‘183⁄4 per-
cent’’. 
(c) LEASES ON LAND KNOWN OR BELIEVED TO 
CONTAIN OIL OR NATURAL GAS.—Section 17 of the Min-
eral Leasing Act (30 U.S.C. 226) is amended— 
(1) in subsection (b)— 
(A) in paragraph (1)(A), in the fifth sen-
tence, by striking ‘‘162⁄3 percent’’ each place it 
appears and inserting ‘‘183⁄4 percent’’; and 
(B) in paragraph (2)(A)(ii), by striking 
‘‘162⁄3 per centum’’ and inserting ‘‘not less than 
183⁄4 percent’’; 
(2) in subsection (l), by striking ‘‘162⁄3 per cen-
tum’’ each place it appears and inserting ‘‘183⁄4 per-
cent’’; and 
(3) in subsection (n)(1)(C), by striking ‘‘162⁄3 
per centum’’ and inserting ‘‘not less than 183⁄4 per-
cent’’. 
SEC. 104. OFFSHORE OIL AND GAS ROYALTY RATE. 
Section 8(a)(1) of the Outer Continental Shelf Lands 
Act (43 U.S.C. 1337(a)(1)) is amended by striking ‘‘but 
not more than 183⁄4 percent, during the 10-year period 
beginning on the date of enactment of the Act titled ‘An 
Act to provide for reconciliation pursuant to title II of S. 
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Con. Res. 14’, and not less than 162⁄3 percent thereafter,’’ 
each place it appears. 
SEC. 105. ELIMINATION OF INTEREST PAYMENTS FOR ROY-
ALTY OVERPAYMENTS. 
Section 111 of the Federal Oil and Gas Royalty Man-
agement Act of 1982 (30 U.S.C. 1721) is amended by 
adding at the end the following: 
‘‘(k) PAYMENT OF INTEREST.—Interest shall not be 
paid on any overpayment.’’. 
SEC. 106. REMOVAL OF LIMITS ON LIABILITY FOR OFF-
SHORE FACILITIES AND PIPELINE OPERA-
TORS. 
Section 1004(a) of the Oil Pollution Act of 1990 (33 
U.S.C. 2704(a)) is amended— 
(1) in paragraph (3), by striking ‘‘plus 
$75,000,000; and’’ and inserting ‘‘and the liability 
of the responsible party under section 1002;’’; 
(2) in paragraph (4)— 
(A) by inserting ‘‘(except an onshore pipe-
line transporting diluted bitumen, bituminous 
mixtures, or any oil manufactured from bitu-
men)’’ after ‘‘for any onshore facility’’; and 
(B) by striking the period at the end and 
inserting ‘‘; and’’; and 
(3) by adding at the end the following: 
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‘‘(5) for any onshore facility transporting di-
luted bitumen, bituminous mixtures, or any oil man-
ufactured from bitumen, the liability of the respon-
sible party under section 1002.’’. 
SEC. 107. RESTRICTIONS ON USE OF APPROPRIATED 
FUNDS BY INTERNATIONAL FINANCIAL INSTI-
TUTIONS FOR PROJECTS THAT SUPPORT 
FOSSIL FUEL. 
(a) DEFINITION OF INTERNATIONAL FINANCIAL IN-
STITUTION.—In this section, the term ‘‘international fi-
nancial institution’’ means— 
(1) each institution described in section 
1701(c)(2) of the International Financial Institu-
tions Act (22 U.S.C. 262r(c)(2)); and 
(2) the North American Development Bank. 
(b) RESCISSION OF UNOBLIGATED FUNDS.— 
(1) IN GENERAL.—Of the unobligated balance 
of amounts appropriated or otherwise made available 
for a contribution of the United States to an inter-
national financial institution, an amount specified in 
paragraph (2) shall be rescinded if the institution 
provides support for a project that supports the pro-
duction or use of fossil fuels. 
(2) AMOUNT SPECIFIED.—The amount specified 
in this paragraph is an amount the Secretary of the 
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Treasury determines to be equivalent to the amount 
of support provided by an international financial in-
stitution described in paragraph (1) for a project 
that supports the production or use of fossil fuels. 
(c) PROHIBITION ON USE OF FUTURE FUNDS.—No 
amounts appropriated or otherwise made available for a 
contribution of the United States to an international fi-
nancial institution may be provided to the institution un-
less the institution agrees to not use the amount to provide 
support for any project that supports the production or 
use of fossil fuels. 
SEC. 108. OFFICE OF FOSSIL ENERGY AND CARBON MAN-
AGEMENT. 
(a) TERMINATION OF AUTHORITY.—Notwithstanding 
any other provision of law, the authority of the Secretary 
of Energy to carry out the Office of Fossil Energy and 
Carbon Management of the Department of Energy is ter-
minated. 
(b) RESCISSION.—Notwithstanding any other provi-
sion of law— 
(1) all amounts made available for the Office of 
Fossil Energy and Carbon Management that remain 
unobligated as of the date of enactment of this Act 
are rescinded; and 
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(2) no amounts made available after the date of 
enactment of this Act for the Office of Fossil En-
ergy and Carbon Management shall be expended, 
other than such amounts as are necessary to cover 
costs incurred in terminating ongoing research of 
the Office of Fossil Energy and Carbon Manage-
ment, as determined by the Secretary of Energy, in 
consultation with other appropriate Federal agen-
cies. 
SEC. 109. LOAN PROGRAMS OFFICE OF THE DEPARTMENT 
OF ENERGY . 
(a) PROHIBITION.—Subject to subsection (b), none of 
the funds made available to the Loan Programs Office of 
the Department of Energy shall be used to carry out any 
project that supports fossil fuel, carbon capture, or hydro-
gen. 
(b) EXCEPTION.—The prohibition on the use of funds 
for hydrogen projects under subsection (a) does not apply 
to projects that support qualified clean hydrogen (as de-
fined in section 45V(c) of the Internal Revenue Code of 
1986 (as amended by section 224(a)(3))). 
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SEC. 110. USDA ASSISTANCE FOR CARBON CAPTURE AND 
STORAGE SYSTEMS. 
Section 9003(j)(1) of the Farm Security and Rural 
Investment Act of 2002 (7 U.S.C. 8103(j)(1)) is amend-
ed— 
(1) by inserting ‘‘and’’ after ‘‘renewable energy 
systems,’’; and 
(2) by striking ‘‘and carbon capture and stor-
age systems,’’. 
SEC. 111. ADVANCED RESEARCH PROJECTS AGENCY—EN-
ERGY. 
None of the funds made available to the Advanced 
Research Projects Agency—Energy shall be used to carry 
out any project that supports fossil fuel. 
SEC. 112. INCENTIVES FOR INNOVATIVE TECHNOLOGIES. 
(a) IN GENERAL.—Section 1703 of the Energy Policy 
Act of 2005 (42 U.S.C. 16513) is amended— 
(1) in subsection (b)— 
(A) by striking paragraphs (2) and (10); 
and 
(B) by redesignating paragraphs (3), (4), 
(5), (6), (7), (8), (9), (11), (12), and (13) as 
paragraphs (2), (3), (4), (5), (6), (7), (8), (9), 
(10), and (11) respectively; 
(2) by striking subsection (c); and 
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(3) by redesignating subsections (d) through (f) 
as subsections (c) through (e), respectively. 
(b) CONFORMING AMENDMENT.—Section 1704 of the 
Energy Policy Act of 2005 (42 U.S.C. 16514) is amend-
ed— 
(1) by striking subsection (b); and 
(2) by redesignating subsection (c) as sub-
section (b). 
SEC. 113. RURAL UTILITY SERVICE LOAN GUARANTEES. 
Notwithstanding any other provision of law, the Sec-
retary of Agriculture may not make a loan under title III 
of the Rural Electrification Act of 1936 (7 U.S.C. 931 
et seq.) to an applicant for the purpose of carrying out 
any project that will use fossil fuel. 
SEC. 114. PROHIBITION ON USE OF FUNDS BY THE UNITED 
STATES INTERNATIONAL DEVELOPMENT FI-
NANCE CORPORATION OR THE EXPORT-IM-
PORT BANK OF THE UNITED STATES FOR FI-
NANCING 
PROJECTS, 
TRANSACTIONS, 
OR 
OTHER ACTIVITIES THAT SUPPORT FOSSIL 
FUEL. 
Notwithstanding any other provision of law, no 
amounts appropriated or otherwise made available for the 
United States International Development Finance Cor-
poration, the Export-Import Bank of the United States, 
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the United States Trade and Development Agency, the 
United States Agency for International Development, or 
the Millennium Challenge Corporation that are available 
for obligation on or after the date of enactment of this 
Act may be obligated or expended to support any project, 
transaction, or other activity that supports the production 
or use of fossil fuels. 
SEC. 115. TRANSPORTATION FUNDS FOR GRANTS, LOANS, 
LOAN GUARANTEES, AND OTHER DIRECT AS-
SISTANCE. 
Notwithstanding any other provision of law, any 
amounts made available to the Department of Transpor-
tation (including the Federal Railroad Administration) 
may not be used to award any grant, loan, loan guarantee, 
or provide any other direct assistance to any rail facility 
or port project that transports fossil fuel. 
SEC. 116. ELIMINATION OF EXCLUSION OF CERTAIN LEND-
ERS AS OWNERS OR OPERATORS UNDER 
CERCLA. 
Section 101(20)(F) of the Comprehensive Environ-
mental Response, Compensation, and Liability Act of 
1980 (42 U.S.C. 9601(20)(F)) is amended by adding at 
the end the following: 
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‘‘(iii) INELIGIBLE LENDERS.—The ex-
clusions under clauses (i) and (ii) shall not 
apply to a person that is a lender that is— 
‘‘(I) an investment company reg-
istered under the Investment Com-
pany Act of 1940 (15 U.S.C. 80a–1 et 
seq.), an investment adviser (as de-
fined in section 202(a) of the Invest-
ment Advisers Act of 1940 (15 U.S.C. 
80b–2(a))), or a broker or dealer (as 
those terms are defined in section 
3(a) of the Securities Exchange Act of 
1934 
(15 
U.S.C. 
78c(a))) 
with 
$250,000,000,000 or more in assets 
under management; or 
‘‘(II) a bank holding company (as 
defined in section 2 of the Bank Hold-
ing Company Act of 1956 (12 U.S.C. 
1841)) with $10,000,000,000 or more 
in total consolidated assets.’’. 
SEC. 117. POWDER RIVER BASIN. 
(a) DESIGNATION OF THE POWDER RIVER BASIN AS 
A COAL PRODUCING REGION.—As soon as practicable 
after the date of enactment of this Act, the Director of 
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the Bureau of Land Management shall designate the Pow-
der River Basin as a coal producing region. 
(b) REPORT.—Not later than 1 year after the date 
of enactment of this Act, the Director of the Bureau of 
Land Management shall submit to Congress a report that 
includes— 
(1) a study of the fair market value and the 
amount and effective rate of royalties paid on coal 
leases in the Powder River Basin compared to other 
national and international coal basins and markets; 
and 
(2) any policy recommendations to capture the 
future market value of the coal leases in the Powder 
River Basin. 
TITLE II—AMENDMENTS TO IN-
TERNAL REVENUE CODE OF 
1986 
SEC. 201. TERMINATION OF VARIOUS TAX EXPENDITURES 
RELATING TO FOSSIL FUELS. 
(a) IN GENERAL.—Subchapter C of chapter 80 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new section: 
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‘‘SEC. 7875. TERMINATION OF CERTAIN PROVISIONS RELAT-
ING TO FOSSIL-FUEL INCENTIVES. 
‘‘(a) IN GENERAL.—The following provisions shall 
not apply to taxable years beginning after the date of the 
enactment of the End Polluter Welfare Act of 2024: 
‘‘(1) Section 43 (relating to enhanced oil recov-
ery credit). 
‘‘(2) Section 45I (relating to credit for pro-
ducing oil and natural gas from marginal wells). 
‘‘(3) Section 461(i)(2) (relating to special rule 
for spudding of oil or natural gas wells). 
‘‘(4) Section 469(c)(3)(A) (relating to working 
interests in oil and natural gas property). 
‘‘(5) Section 613A (relating to limitations on 
percentage depletion in case of oil and natural gas 
wells). 
‘‘(b) PROVISIONS RELATING
TO PROPERTY.—The 
following provisions shall not apply to property placed in 
service after the date of the enactment of the End Polluter 
Welfare Act of 2024: 
‘‘(1) Section 168(e)(3)(C)(iii) (relating to clas-
sification of certain property). 
‘‘(2) Section 169 (relating to amortization of 
pollution control facilities) with respect to any at-
mospheric pollution control facility. 
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‘‘(c) PROVISIONS RELATING
TO COSTS
AND EX-
PENSES.—The following provisions shall not apply to costs 
or expenses paid or incurred after the date of the enact-
ment of the End Polluter Welfare Act of 2024: 
‘‘(1) Section 179B (relating to deduction for 
capital costs incurred in complying with Environ-
mental Protection Agency sulfur regulations). 
‘‘(2) Section 468 (relating to special rules for 
mining and solid waste reclamation and closing 
costs). 
‘‘(d) ALLOCATED CREDITS.—No new credits shall be 
certified under section 48A (relating to qualifying ad-
vanced coal project credit) after the date of the enactment 
of the End Polluter Welfare Act of 2024. 
‘‘(e) ARBITRAGE BONDS.—Section 148(b)(4) (relat-
ing to safe harbor for prepaid natural gas) shall not apply 
to obligations issued after the date of the enactment of 
the End Polluter Welfare Act of 2024.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 613(d) of the Internal Revenue 
Code of 1986 is amended by striking ‘‘Except as 
provided in section 613A, in the case’’ and inserting 
‘‘In the case’’. 
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(2) The table of sections for subchapter C of 
chapter 90 of such Code is amended by adding at 
the end the following new item: 
‘‘Sec. 7875. Termination of certain provisions relating to fossil-fuel incentives.’’. 
SEC. 202. TERMINATION OF CERTAIN DEDUCTIONS AND 
CREDITS RELATED TO FOSSIL FUELS. 
(a) SPECIAL
ALLOWANCE
FOR
CERTAIN
PROP-
ERTY.—Section 168(k) of the Internal Revenue Code of 
1986 is amended by adding at the end the following: 
‘‘(11) FOSSIL FUEL PROPERTY.— 
‘‘(A) IN GENERAL.—This subsection shall 
not apply with respect to any property which is 
primarily used for fossil fuel activities and is 
placed in service during any taxable year begin-
ning after the date of the enactment of the End 
Polluter Welfare Act of 2024. 
‘‘(B) FOSSIL FUEL ACTIVITIES.—For pur-
poses of this paragraph, the term ‘fossil fuel ac-
tivities’ means the exploration, development, 
mining or production, processing, refining, 
transportation (including pipelines transporting 
gas, oil, or products thereof), distribution, or 
marketing of coal, petroleum, natural gas, or 
any derivative of coal, petroleum, or natural gas 
that is used for fuel. 
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‘‘(C) EXCEPTION.—The property described 
in subparagraph (A) shall not include any 
motor vehicle service station or convenience 
store which does not qualify as a retail motor 
fuels outlet under subsection (e)(3)(E)(iii).’’. 
(b) 
QUALIFIED
BUSINESS
INCOME.—Section 
199A(c)(3)(B) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following: 
‘‘(viii) Any item of gain or loss de-
rived from fossil fuel activities (as defined 
in section 168(k)(11)(B)) during any tax-
able year beginning after the date of the 
enactment of the End Polluter Welfare Act 
of 2024.’’. 
(c) CREDIT
FOR INCREASING RESEARCH ACTIVI-
TIES.—Section 41(d)(4) of the Internal Revenue Code of 
1986 is amended by adding at the end the following: 
‘‘(I) FOSSIL
FUEL
ACTIVITIES.—Any re-
search related to fossil fuel activities (as defined 
in section 168(k)(11)(B)) which is conducted 
after the date of the enactment of the End Pol-
luter Welfare Act of 2024.’’. 
(d) FOREIGN-DERIVED INTANGIBLE INCOME.—Sub-
clause (V) of section 250(b)(3)(A)(i) of the Internal Rev-
enue Code of 1986 is amended to read as follows: 
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‘‘(V) any income derived from 
fossil fuel activities (as defined in sec-
tion 168(k)(11)(B)) during any tax-
able year beginning after the date of 
the enactment of the End Polluter 
Welfare Act of 2024, and’’. 
(e) EXCHANGE OF REAL PROPERTY HELD FOR PRO-
DUCTIVE USE OR INVESTMENT.—Section 1031(a)(2) of 
the Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(2) EXCEPTIONS.—This subsection shall not 
apply to— 
‘‘(A) any exchange of real property held 
primarily for sale, or 
‘‘(B) any exchange of real property 
which— 
‘‘(i) is used for fossil fuel activities (as 
defined in section 168(k)(11)(B)), and 
‘‘(ii) occurs after the date of the en-
actment of the End Polluter Welfare Act 
of 2024.’’. 
SEC. 203. UNIFORM SEVEN-YEAR AMORTIZATION FOR GEO-
LOGICAL AND GEOPHYSICAL EXPENDITURES. 
(a) IN GENERAL.—Section 167(h) of the Internal 
Revenue Code of 1986 is amended— 
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(1) by striking ‘‘24-month period’’ each place it 
appears in paragraphs (1) and (4) and inserting 
‘‘84-month period’’, 
(2) by striking paragraph (2) and inserting the 
following: 
‘‘(2) MID-MONTH CONVENTION.—For purposes 
of paragraph (1), any payment paid or incurred dur-
ing any month shall be treated as paid or incurred 
on the mid-point of such month.’’, and 
(3) by striking paragraph (5). 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to amounts paid or incurred after 
the date of the enactment of this Act. 
SEC. 204. NATURAL GAS GATHERING LINES TREATED AS 15- 
YEAR PROPERTY. 
(a) IN GENERAL.—Section 168(e)(3)(E) of the Inter-
nal Revenue Code of 1986 is amended by striking ‘‘and’’ 
at the end of clause (vi), by striking the period at the end 
of clause (vii) and inserting ‘‘, and’’, and by adding at 
the end the following new clause: 
‘‘(viii) any natural gas gathering line 
the original use of which commences with 
the taxpayer after the date of the enact-
ment of this clause.’’. 
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(b) ALTERNATIVE SYSTEM.—The table contained in 
section 168(g)(3)(B) of the Internal Revenue Code of 
1986 is amended by inserting after the item relating to 
subparagraph (E)(vii) the following new item: 
‘‘(E)(viii)
.................................................................................................
22’’. 
(c) CONFORMING AMENDMENT.—Clause (iv) of sec-
tion 168(e)(3)(C) of the Internal Revenue Code of 1986 
is amended by inserting ‘‘and on or before the date of the 
enactment of the End Polluter Welfare Act of 2024’’ after 
‘‘April 11, 2005’’. 
(d) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendments made by 
this section shall apply to property placed in service 
on and after the date of the enactment of this Act. 
(2) EXCEPTION.—The amendments made by 
this section shall not apply to any property with re-
spect to which the taxpayer or a related party has 
entered into a binding contract for the construction 
thereof on or before the date of the introduction of 
this Act, or, in the case of self-constructed property, 
has started construction on or before such date. 
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(2) OIL
SHALE.—Section 613(b)(2) of such 
Code is amended to read as follows: 
‘‘(2) 15 PERCENT.—If, from deposits in the 
United States, gold, silver, copper, and iron ore.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 207. TERMINATION OF CAPITAL GAINS TREATMENT 
FOR ROYALTIES FROM COAL. 
(a) IN GENERAL.—Subsection (c) of section 631 of 
the Internal Revenue Code of 1986 is amended— 
(1) by striking ‘‘coal (including lignite), or iron 
ore’’ and inserting ‘‘iron ore’’, 
(2) by striking ‘‘coal or iron ore’’ each place it 
appears and inserting ‘‘iron ore’’, 
(3) by striking ‘‘iron ore or coal’’ each place it 
appears and inserting ‘‘iron ore’’, and 
(4) by striking ‘‘COAL OR’’ in the heading. 
(b) CONFORMING AMENDMENTS.— 
(1) The heading of section 631 of the Internal 
Revenue Code of 1986 is amended by striking ‘‘, 
COAL,’’. 
(2) Section 1231(b)(2) of such Code is amend-
ed by striking ‘‘, coal,’’. 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to dispositions after the date of 
the enactment of this Act. 
SEC. 208. MODIFICATIONS OF FOREIGN TAX CREDIT RULES 
APPLICABLE TO OIL AND GAS INDUSTRY TAX-
PAYERS 
RECEIVING 
SPECIFIC 
ECONOMIC 
BENEFITS. 
(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 DUAL CAPACITY 
TAXPAYERS.— 
‘‘(1) GENERAL
RULE.—Notwithstanding any 
other provision of this chapter, any amount paid or 
accrued to a foreign country or possession of the 
United States for any period by a dual capacity tax-
payer which is in the trade or business of the pro-
duction, refining, processing, transportation, or dis-
tribution of fossil fuel shall not be considered a 
tax— 
‘‘(A) if, for such period, the foreign coun-
try or possession does not impose a generally 
applicable income tax, or 
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‘‘(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 no amount other 
than the amount required to be paid by 
such taxpayer under the generally applica-
ble income tax imposed by the country or 
possession were paid or accrued by 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 
subparagraph (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 
‘‘(B) receives (or will receive) directly or 
indirectly a specific economic benefit (as deter-
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mined in accordance with regulations) from 
such country or possession. 
‘‘(3) GENERALLY APPLICABLE INCOME TAX.— 
For purposes of this subsection— 
‘‘(A) IN
GENERAL.—The term ‘generally 
applicable income tax’ means an income tax (or 
a series of income taxes) which is generally im-
posed under the laws of a foreign country or 
possession on income derived from the conduct 
of a trade or business within such country or 
possession. 
‘‘(B) EXCEPTIONS.—Such term shall not 
include a tax unless it has substantial applica-
tion, by its terms and in practice, to— 
‘‘(i) persons who are not dual capacity 
taxpayers, and 
‘‘(ii) persons who are— 
‘‘(I) citizens or residents of the 
foreign country or possession, or 
‘‘(II) organized or incorporated 
under the laws of the foreign country 
or possession. 
‘‘(4) FOSSIL FUEL.—For purposes of this sub-
section, the term ‘fossil fuel’ means coal, petroleum, 
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natural gas, or any derivative of coal, petroleum, or 
natural gas that is used for fuel.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxes paid or accrued in taxable 
years beginning after the date of the enactment of this 
Act. 
(c) 
SPECIAL
RULE
FOR
TREATIES.—Notwith-
standing sections 894 or 7852(d) of the Internal Revenue 
Code of 1986, the amendments made by this section shall 
apply without regard to any treaty obligation of the 
United States. 
SEC. 209. INCREASE IN OIL SPILL LIABILITY TRUST FUND 
FINANCING RATE. 
(a) IN GENERAL.—Section 4611 of the Internal Rev-
enue Code of 1986 is amended— 
(1) in subsection (c)(2)(B)— 
(A) in clause (i), by striking ‘‘and’’ at the 
end, 
(B) in clause (ii), by striking the period at 
the end and inserting ‘‘, and’’, and 
(C) by adding at the end the following: 
‘‘(iii) in the case of crude oil received 
or petroleum products entered after De-
cember 31, 2024, 10 cents a barrel.’’, and 
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(2) by striking subsection (f) and inserting the 
following: 
‘‘(f) APPLICATION OF OIL SPILL LIABILITY TRUST 
FUND FINANCING RATE.—The Oil Spill Liability Trust 
Fund financing rate under subsection (c) shall apply on 
and after April 1, 2006, or if later, the date which is 30 
days after the last day of any calendar quarter for which 
the Secretary estimates that, as of the close of that quar-
ter, the unobligated balance in the Oil Spill Liability Trust 
Fund is less than $2,000,000,000.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to crude oil received and petroleum 
products entered after December 31, 2024. 
SEC. 210. APPLICATION OF CERTAIN ENVIRONMENTAL 
TAXES TO SYNTHETIC CRUDE OIL. 
(a) IN GENERAL.—Paragraph (1) of section 4612(a) 
of the Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(1) CRUDE OIL.— 
‘‘(A) IN GENERAL.—The term ‘crude oil’ 
includes crude oil condensates, natural gasoline, 
and synthetic crude oil. 
‘‘(B) SYNTHETIC
CRUDE
OIL.—For pur-
poses of subparagraph (A), the term ‘synthetic 
crude oil’ means— 
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‘‘(i) any bitumen and bituminous mix-
tures, 
‘‘(ii) any oil derived from bitumen and 
bituminous mixtures (including oil derived 
from tar sands), 
‘‘(iii) any liquid fuel derived from 
coal, and 
‘‘(iv) any oil derived from kerogen- 
bearing sources (including oil derived from 
oil shale).’’. 
(b) REGULATORY AUTHORITY TO ADDRESS OTHER 
TYPES OF CRUDE OIL AND PETROLEUM PRODUCTS.— 
Subsection (a) of section 4612 of the Internal Revenue 
Code of 1986 is amended by adding at the end the fol-
lowing: 
‘‘(10) REGULATORY
AUTHORITY
TO
ADDRESS 
OTHER
TYPES
OF
CRUDE
OIL
AND
PETROLEUM 
PRODUCTS.—Under such regulations as the Sec-
retary may prescribe, the Secretary may include as 
crude oil or as a petroleum product subject to tax 
under section 4611, any fuel feedstock or finished 
fuel product customarily transported by pipeline, 
vessel, railcar, or tanker truck if the Secretary deter-
mines that— 
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‘‘(A) the classification of such fuel feed-
stock or finished fuel product is consistent with 
the definition of oil under the Oil Pollution Act 
of 1990, and 
‘‘(B) such fuel feedstock or finished fuel 
product is produced in sufficient commercial 
quantities as to pose a significant risk of haz-
ard in the event of a discharge.’’. 
(c) TECHNICAL AMENDMENT.—Paragraph (2) of sec-
tion 4612(a) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘from a well located’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to oil and petroleum products re-
ceived or entered during calendar quarters beginning more 
than 60 days after the date of the enactment of this Act. 
SEC. 211. DENIAL OF DEDUCTION FOR REMOVAL COSTS 
AND DAMAGES FOR CERTAIN OIL SPILLS. 
(a) IN GENERAL.—Section 162(f) of the Internal 
Revenue Code of 1986 is amended— 
(1) by redesignating paragraph (5) as para-
graph (6), and 
(2) by inserting after paragraph (4) the fol-
lowing: 
‘‘(5) EXPENSES
FOR
REMOVAL
COSTS
AND 
DAMAGES RELATING TO CERTAIN OIL SPILL LIABIL-
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ITY.—Notwithstanding paragraphs (2) and (3), no 
deduction shall be allowed under this chapter for any 
costs or damages for which the taxpayer is liable 
under section 1002 of the Oil Pollution Act of 1990 
(33 U.S.C. 2702)’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply with respect to any liability arising 
in taxable years ending after the date of the enactment 
of this Act. 
SEC. 212. TAX ON CRUDE OIL AND NATURAL GAS PRO-
DUCED FROM THE OUTER CONTINENTAL 
SHELF IN THE GULF OF MEXICO. 
(a) IN GENERAL.—Subtitle E of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new chapter: 
‘‘CHAPTER 56—TAX ON SEVERANCE OF 
CRUDE OIL AND NATURAL GAS FROM 
THE OUTER CONTINENTAL SHELF IN 
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. 
‘‘SEC. 5901. IMPOSITION OF TAX. 
‘‘(a) IN GENERAL.—In addition to any other tax im-
posed under this title, there is hereby imposed a tax equal 
to 13 percent of the removal price of any taxable crude 
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oil or natural gas removed from the premises during any 
taxable period. 
‘‘(b) CREDIT FOR FEDERAL ROYALTIES PAID.— 
‘‘(1) IN GENERAL.—There shall be allowed as a 
credit against the tax imposed by subsection (a) with 
respect to the production of any taxable crude oil or 
natural gas an amount equal to the aggregate 
amount of royalties paid under Federal law with re-
spect to such production. 
‘‘(2) LIMITATION.—The aggregate amount of 
credits allowed under paragraph (1) to any taxpayer 
for any taxable period shall not exceed the amount 
of tax imposed by subsection (a) for such taxable pe-
riod. 
‘‘(c) TAX PAID BY PRODUCER.—The tax imposed by 
this section shall be paid by the producer of the taxable 
crude oil or natural gas. 
‘‘SEC. 5902. TAXABLE CRUDE OIL OR NATURAL GAS AND RE-
MOVAL PRICE. 
‘‘(a) TAXABLE CRUDE OIL OR NATURAL GAS.—For 
purposes of this chapter, the term ‘taxable crude oil or 
natural gas’ means crude oil or natural gas which is pro-
duced from Federal submerged lands on the outer Conti-
nental Shelf in the Gulf of Mexico pursuant to a lease 
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entered into with the United States which authorizes the 
production. 
‘‘(b) REMOVAL PRICE.—For purposes of this chap-
ter— 
‘‘(1) IN GENERAL.—Except as otherwise pro-
vided in this subsection, the term ‘removal price’ 
means— 
‘‘(A) in the case of taxable crude oil, the 
amount for which a barrel of such crude oil is 
sold, and 
‘‘(B) in the case of taxable natural gas, the 
amount per 1,000 cubic feet for which such 
natural gas is sold. 
‘‘(2) SALES BETWEEN RELATED PERSONS.—In 
the case of a sale between related persons, the re-
moval price shall not be less than the constructive 
sales price for purposes of determining gross income 
from the property under section 613. 
‘‘(3) OIL
OR
NATURAL
GAS
REMOVED
FROM 
PROPERTY BEFORE SALE.—If crude oil or natural 
gas is removed from the property before it is sold, 
the removal price shall be the constructive sales 
price for purposes of determining gross income from 
the property under section 613. 
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‘‘(4) REFINING BEGUN ON PROPERTY.—If the 
manufacture or conversion of crude oil into refined 
products begins before such oil is removed from the 
property— 
‘‘(A) such oil shall be treated as removed 
on the day such manufacture or conversion be-
gins, and 
‘‘(B) the removal price shall be the con-
structive sales price for purposes of determining 
gross income from the property under section 
613. 
‘‘(5) PROPERTY.—The term ‘property’ has the 
meaning given such term by section 614. 
‘‘SEC. 5903. SPECIAL RULES AND DEFINITIONS. 
‘‘(a) ADMINISTRATIVE REQUIREMENTS.— 
‘‘(1) WITHHOLDING AND DEPOSIT OF TAX.— 
The Secretary shall provide for the withholding and 
deposit of the tax imposed under section 5901 on a 
quarterly basis. 
‘‘(2) RECORDS AND INFORMATION.—Each tax-
payer liable for tax under section 5901 shall keep 
such records, make such returns, and furnish such 
information (to the Secretary and to other persons 
having an interest in the taxable crude oil or natural 
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gas) with respect to such oil as the Secretary may 
by regulations prescribe. 
‘‘(3) TAXABLE PERIODS; RETURN OF TAX.— 
‘‘(A) TAXABLE PERIOD.—Except as pro-
vided by the Secretary, each calendar year shall 
constitute a taxable period. 
‘‘(B) RETURNS.—The Secretary shall pro-
vide for the filing, and the time for filing, of the 
return of the tax imposed under section 5901. 
‘‘(b) DEFINITIONS.—For purposes of this chapter— 
‘‘(1) PRODUCER.—The term ‘producer’ means 
the holder of the economic interest with respect to 
the crude oil or natural gas. 
‘‘(2) CRUDE OIL.—The term ‘crude oil’ includes 
crude oil condensates and natural gasoline. 
‘‘(3) PREMISES AND CRUDE OIL PRODUCT.— 
The terms ‘premises’ and ‘crude oil product’ have 
the same meanings as when used for purposes of de-
termining gross income from the property under sec-
tion 613. 
‘‘(c) ADJUSTMENT OF REMOVAL PRICE.—In deter-
mining the removal price of oil or natural gas from a prop-
erty in the case of any transaction, the Secretary may ad-
just the removal price to reflect clearly the fair market 
value of oil or natural gas removed. 
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‘‘(d) REGULATIONS.—The Secretary shall prescribe 
such regulations as may be necessary or appropriate to 
carry out the purposes of this chapter.’’. 
(b) DEDUCTIBILITY OF TAX.—The first sentence of 
section 164(a) of the Internal Revenue Code of 1986 is 
amended by inserting after paragraph (4) the following 
new paragraph: 
‘‘(5) The tax imposed by section 5901(a) (after 
application of section 5901(b)) on the severance of 
crude oil or natural gas from the outer Continental 
Shelf in the Gulf of Mexico.’’. 
(c) CLERICAL AMENDMENT.—The table of chapters 
for subtitle E is amended by adding at the end the fol-
lowing new item: 
‘‘CHAPTER 56. Tax on severance of crude oil and natural gas 
from the outer Continental Shelf in the Gulf of 
Mexico.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to crude oil or natural gas removed 
after December 31, 2024. 
SEC. 213. REPEAL OF CORPORATE INCOME TAX EXEMP-
TION FOR PUBLICLY TRADED PARTNERSHIPS 
WITH QUALIFYING INCOME AND GAINS FROM 
ACTIVITIES RELATING TO FOSSIL FUELS. 
(a) IN GENERAL.—Section 7704(d)(1) of the Inter-
nal Revenue Code of 1986 is amended by inserting ‘‘or 
any coal, petroleum, natural gas, or any derivative of coal, 
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petroleum, or natural gas that is used for fuel’’ after ‘‘sec-
tion 613(b)(7)’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 
214. 
AMORTIZATION 
OF 
QUALIFIED 
TERTIARY 
INJECTANT EXPENSES. 
(a) IN GENERAL.—Section 193 of the Internal Rev-
enue Code of 1986 is amended— 
(1) by striking subsection (a) and inserting the 
following: 
‘‘(a) AMORTIZATION
OF
QUALIFIED
TERTIARY 
INJECTANT EXPENSES.— 
‘‘(1) IN
GENERAL.—Any qualified tertiary 
injectant expenses paid or incurred by the taxpayer 
shall be allowed as a deduction ratably over the 84- 
month period beginning on the date that such ex-
pense was paid or incurred. 
‘‘(2) MID-MONTH CONVENTION.—For purposes 
of paragraph (1), any expenses paid or incurred dur-
ing any month shall be treated as paid or incurred 
on the mid-point of such month.’’, and 
(2) by striking subsection (c) and inserting the 
following: 
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‘‘(c) EXCLUSIVE METHOD.—Except as provided in 
this section, no depreciation or amortization deduction 
shall be allowed with respect to qualified tertiary injectant 
expenses.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to expenses paid or incurred in 
taxable years beginning after the date of the enactment 
of this Act. 
SEC. 215. AMORTIZATION OF DEVELOPMENT EXPENDI-
TURES. 
(a) IN GENERAL.—Section 616 of the Internal Rev-
enue Code of 1986 is amended to read as follows: 
‘‘SEC. 616. AMORTIZATION OF DEVELOPMENT EXPENDI-
TURES. 
‘‘(a) IN GENERAL.—Any expenditures paid or in-
curred for the development of a mine or other natural de-
posit (other than an oil or gas well) if paid or incurred 
after the existence of ores or minerals in commercially 
marketable quantities has been disclosed shall be allowed 
as a deduction ratably over the 84-month period beginning 
on the date that such expenditure was paid or incurred. 
‘‘(b) MID-MONTH CONVENTION.—For purposes of 
subsection (a), any expenditures paid or incurred during 
any month shall be treated as paid or incurred on the mid- 
point of such month. 
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‘‘(c) EXCLUSIVE METHOD.—Except as provided in 
this section, no depreciation or amortization deduction 
shall be allowed with respect to expenditures described in 
subsection (a). 
‘‘(d) TREATMENT UPON ABANDONMENT.—If any 
property with respect to which expenditures described in 
subsection (a) are paid or incurred is retired or abandoned 
during the 84-month period described in such subsection, 
no deduction shall be allowed on account of such retire-
ment or abandonment and the amortization deduction 
under this section shall continue with respect to such pay-
ment.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The item relating to section 616 in the table 
of sections for part I of subchapter I of chapter 1 
of the Internal Revenue Code of 1986 is amended to 
read as follows: 
‘‘Sec. 616. Amortization of development expenditures.’’. 
(2) Section 56(a)(2)(A) of such Code is amend-
ed by striking ‘‘616(a) or’’. 
(3) Section 59(e) of such Code is amended— 
(A) in paragraph (2)— 
(i) in subparagraph (C), by inserting 
‘‘or’’ at the end, 
(ii) by striking subparagraph (D), and 
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(iii) by redesignating subparagraph 
(E) as subparagraph (D), and 
(B) in paragraph (5)(A), by striking ‘‘, 
616(a),’’. 
(4) Section 263(a)(1) of such Code is amended 
by striking subparagraph (A). 
(5) Section 263A(c)(3) of such Code is amend-
ed by striking ‘‘616,’’. 
(6) Section 291(b) of such Code is amended— 
(A) in paragraph (1)(B), by striking 
‘‘616(a) or’’, 
(B) in paragraph (2), by striking ‘‘, 
616(a),’’, and 
(C) in paragraph (3), by striking ‘‘, 
616(a),’’. 
(7) Section 312(n)(2)(B) of such Code is 
amended by striking ‘‘616(a) or’’. 
(8) Section 381(c) of such Code is amended by 
striking paragraph (10). 
(9) Section 1016(a) of such Code is amended 
by striking paragraph (9). 
(10) Section 1254(a)(1)(A)(i) of such Code is 
amended by striking ‘‘, 616,’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to expenditures paid or incurred 
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in taxable years beginning after the date of the enactment 
of this Act. 
SEC. 216. AMORTIZATION OF CERTAIN MINING EXPLO-
RATION EXPENDITURES. 
(a) IN GENERAL.—Section 617 of the Internal Rev-
enue Code of 1986 is amended to read as follows: 
‘‘SEC. 617. AMORTIZATION OF CERTAIN MINING EXPLO-
RATION EXPENDITURES. 
‘‘(a) IN GENERAL.—Any expenditures paid or in-
curred for the purpose of ascertaining the existence, loca-
tion, extent, or quality of any deposit of ore or other min-
eral, and paid or incurred before the beginning of the de-
velopment stage of the mine, shall be allowed as a deduc-
tion ratably over the 84-month period beginning on the 
date that such expense was paid or incurred. 
‘‘(b) MID-MONTH CONVENTION.—For purposes of 
subsection (a), any expenditures paid or incurred during 
any month shall be treated as paid or incurred on the mid- 
point of such month. 
‘‘(c) EXCLUSIVE METHOD.—Except as provided in 
this section, no depreciation or amortization deduction 
shall be allowed with respect to expenditures described in 
subsection (a). 
‘‘(d) TREATMENT UPON ABANDONMENT.—If any 
property with respect to which expenditures described in 
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subsection (a) are paid or incurred is retired or abandoned 
during the 84-month period described in such subsection, 
no deduction shall be allowed on account of such retire-
ment or abandonment and the amortization deduction 
under this section shall continue with respect to such pay-
ment.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The item relating to section 617 in the table 
of sections for part I of subchapter I of chapter 1 
of the Internal Revenue Code of 1986 is amended to 
read as follows: 
‘‘Sec. 617. Amortization of certain mining exploration expenditures.’’. 
(2) Section 56(a) of such Code, as amended by 
section 215(b)(2), is amended by striking paragraph 
(2). 
(3) Section 59(e) of such Code, as amended by 
section 215(b)(3), is amended— 
(A) in paragraph (2)— 
(i) in subparagraph (B), by inserting 
‘‘or’’ at the end, 
(ii) in subparagraph (C), by striking 
the comma at the end and inserting a pe-
riod, and 
(iii) by striking subparagraph (D), 
and 
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(B) by striking paragraph (5) and insert-
ing the following: 
‘‘(5) DISPOSITIONS.—In the case of any dis-
position of property to which section 1254 applies 
(determined without regard to this section), any de-
duction under paragraph (1) with respect to 
amounts which are allocable to such property shall, 
for purposes of section 1254, be treated as a deduc-
tion allowable under section 263(c).’’. 
(4) Section 170(e) of such Code is amended— 
(A) 
in 
paragraph 
(1), 
by 
striking 
‘‘617(d)(1),’’, and 
(B) in paragraph (3)(D), by striking 
‘‘617,’’. 
(5) Section 263A(c)(3) of such Code, as amend-
ed by section 215(b)(5), is amended by striking 
‘‘291(b)(2), or 617’’ and inserting ‘‘or 291(b)(2)’’. 
(6) Section 291(b) of such Code, as amended by 
section 215(b)(6), is amended— 
(A) in the heading, by striking ‘‘AND MIN-
ERAL
EXPLORATION
AND
DEVELOPMENT 
COSTS’’, 
(B) by striking paragraph (1) and insert-
ing the following: 
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‘‘(1) IN
GENERAL.—In the case of an inte-
grated oil company, the amount allowable as a de-
duction for any taxable year (determined without re-
gard to this section) under section 263(c) shall be 
reduced by 30 percent.’’, 
(C) in paragraph (2), by striking ‘‘or 
617(a) (as the case may be)’’, and 
(D) in paragraph (3), by striking ‘‘or 
617(a) (whichever is appropriate)’’. 
(7) Section 312(n), as amended by section 
215(b)(7), is amended by striking paragraph (2) and 
inserting the following: 
‘‘(2) 
INTANGIBLE
DRILLING
COSTS.—Any 
amount allowable as a deduction under section 
263(c) in determining taxable income (other than 
costs incurred in connection with a nonproductive 
well)— 
‘‘(A) shall be capitalized, and 
‘‘(B) shall be allowed as a deduction rat-
ably over the 60-month period beginning with 
the month in which such amount was paid or 
incurred.’’. 
(8) Section 703(b) of such Code is amended— 
(A) in paragraph (1), by adding ‘‘or’’ at 
the end, 
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(B) by striking paragraph (2), and 
(C) by redesignating paragraph (3) as 
paragraph (2). 
(9) Section 751(c) of such Code is amended— 
(A) by inserting ‘‘, as in effect on the day 
before the date of the enactment of the End 
Polluter Welfare Act of 2024’’ after ‘‘section 
617(f)(2)’’, and 
(B) by striking ‘‘617(d)(1),’’. 
(10) Section 1254(a)(1)(A)(i) of such Code, as 
amended by section 215(b)(10), is amended by strik-
ing ‘‘or 617’’. 
(11) Paragraph (2) of section 1363(c) of such 
Code is amended to read as follows: 
‘‘(2) EXCEPTION.—In the case of an S corpora-
tion, elections under section 901 (relating to taxes of 
foreign countries and possessions of the United 
States) shall be made by each shareholder sepa-
rately.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to expenditures paid or incurred 
in taxable years beginning after the date of the enactment 
of this Act. 
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SEC. 217. AMORTIZATION OF INTANGIBLE DRILLING AND 
DEVELOPMENT COSTS IN THE CASE OF OIL 
AND GAS WELLS. 
(a) IN GENERAL.—Subsection (c) of section 263 of 
the Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(c) INTANGIBLE DRILLING
AND DEVELOPMENT 
COSTS IN THE CASE OF OIL AND GAS WELLS AND GEO-
THERMAL WELLS.— 
‘‘(1) GEOTHERMAL
WELLS.—Notwithstanding 
subsection (a), and except as provided in subsection 
(i), a taxpayer may elect to deduct as expenses in-
tangible drilling and development costs in the case 
of wells drilled for any geothermal deposit (as de-
fined in section 613(e)(2)) in such manner as the 
Secretary provides. This subsection shall not apply 
with respect to any costs to which any deduction is 
allowed under section 59(e). 
‘‘(2) OIL
AND
GAS
WELLS.—Notwithstanding 
subsection (a), and except as provided in subsection 
(i), in the case of any expenses paid or incurred in 
taxable years beginning after the date of the enact-
ment of End Polluter Welfare Act of 2024 in con-
nection with intangible drilling and development 
costs related to oil and gas wells— 
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‘‘(A) such expenses shall be allowed as a 
deduction ratably over the 84-month period be-
ginning on the date that such expense was paid 
or incurred, 
‘‘(B) any such expenses paid or incurred 
during any month shall be treated as paid or 
incurred on the mid-point of such month, 
‘‘(C) except as provided in this paragraph, 
no depreciation or amortization deduction shall 
be allowed with respect to such expenses, and 
‘‘(D) if any property with respect to which 
such intangible drilling and development costs 
are paid or incurred is retired or abandoned 
during such 84-month period, no deduction 
shall be allowed on account of such retirement 
or abandonment and the amortization deduction 
under this paragraph shall continue with re-
spect to such payment.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Paragraph (2) of section 57(a) of the Inter-
nal Revenue Code of 1986 is amended to read as fol-
lows: 
‘‘(2) INTANGIBLE DRILLING COSTS.— 
‘‘(A) IN
GENERAL.—With respect to all 
geothermal properties of the taxpayer, the 
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amount (if any) by which the amount of the ex-
cess intangible drilling costs arising in the tax-
able year is greater than 65 percent of the net 
income of the taxpayer from geothermal prop-
erties for the taxable year. 
‘‘(B) 
EXCESS
INTANGIBLE
DRILLING 
COSTS.—For purposes of subparagraph (A), the 
amount of the excess intangible drilling costs 
arising in the taxable year is the excess of— 
‘‘(i) the intangible drilling and devel-
opment costs paid or incurred in connec-
tion with geothermal wells (other than 
costs incurred in drilling a nonproductive 
well) allowable under section 263(c)(1) for 
the taxable year, over 
‘‘(ii) the amount which would have 
been allowable for the taxable year if such 
costs had been capitalized and straight line 
recovery of intangibles (as defined in sub-
section (b)) had been used with respect to 
such costs. 
‘‘(C) NET
INCOME
FROM
GEOTHERMAL 
PROPERTIES.—For purposes of subparagraph 
(A), the amount of the net income of the tax-
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payer from geothermal properties for the tax-
able year is the excess of— 
‘‘(i) the aggregate amount of gross in-
come (within the meaning of section 
613(a)) from all geothermal properties of 
the taxpayer received or accrued by the 
taxpayer during the taxable year, over 
‘‘(ii) the amount of any deductions al-
locable to such properties reduced by the 
excess described in subparagraph (B) for 
such taxable year.’’. 
(2) Section 59(e) of such Code, as amended by 
sections 215 and 216, is amended— 
(A) in paragraph (2)(C), by striking ‘‘sec-
tion 263(c)’’ and inserting ‘‘section 263(c)(1)’’, 
and 
(B) in paragraph (5), by striking ‘‘section 
263(c)’’ and inserting ‘‘section 263(c)(1)’’. 
(3) Section 263A(c)(3) of such Code, as amend-
ed by sections 215 and 216, is amended— 
(A) in the heading, by striking ‘‘OIL AND 
GAS’’ and inserting ‘‘GEOTHERMAL’’, and 
(B) by striking ‘‘263(c),’’ and inserting 
‘‘263(c)(1)’’. 
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(4) Section 291 of such Code, as amended by 
sections 215 and 216, is amended by striking sub-
section (b). 
(5) Section 312(n) of such Code, as amended 
by sections 215 and 216, is amended by striking 
‘‘section 263(c),’’ and inserting ‘‘section 263(c)(1)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to expenditures paid or incurred 
in taxable years beginning after the date of the enactment 
of this Act. 
SEC. 218. INCREASE IN EXCISE TAX RATE FOR FUNDING OF 
BLACK LUNG DISABILITY TRUST FUND. 
(a) IN GENERAL.—Section 4121(b) of the Internal 
Revenue Code of 1986 is amended— 
(1) in paragraph (1), by striking ‘‘$1.10’’ and 
inserting ‘‘$1.38’’, and 
(2) in paragraph (2), by striking ‘‘$.55’’ and in-
serting ‘‘$0.69’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply on and after the first day of the 
first calendar month beginning after the date of the enact-
ment of this Act. 
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SEC. 219. ELIMINATION OF RENEWABLE ELECTRICITY PRO-
DUCTION CREDIT ELIGIBILITY FOR REFINED 
COAL. 
(a) IN GENERAL.—Section 45 of the Internal Rev-
enue Code of 1986 is amended— 
(1) in subsection (b)(2)— 
(A) in the first sentence, by striking ‘‘, the 
8 cent amount’’ and all that follows through ‘‘in 
2002’’ and inserting ‘‘and the 8 cent amount in 
paragraph (1)’’, and 
(B) in the third sentence, by striking ‘‘In 
any other case, if an amount’’ and inserting ‘‘If 
the 8 cent amount’’, 
(2) in subsection (c), by striking paragraph (7), 
(3) in subsection (d), by striking paragraph (8), 
and 
(4) in subsection (e)— 
(A) by striking paragraph (8), and 
(B) by striking paragraph (9) and insert-
ing the following: 
‘‘(9) COORDINATION
WITH
CREDIT
FOR
PRO-
DUCING
FUEL
FROM
A
NONCONVENTIONAL 
SOURCE.—The term ‘qualified facility’ shall not in-
clude any facility which produces electricity from gas 
derived from the biodegradation of municipal solid 
waste if such biodegradation occurred in a facility 
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(within the meaning of section 45K) the production 
from which is allowed as a credit under section 45K 
for the taxable year or any prior taxable year.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 38(c)(4)(B)(iv) of the Internal Rev-
enue Code of 1986 is amended by striking ‘‘or re-
fined coal’’. 
(2) Section 45K(g)(2) of such Code is amended 
by striking subparagraph (E). 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to coal produced after December 
31, 2024. 
SEC. 220. TREATMENT OF FOREIGN OIL RELATED INCOME 
AS SUBPART F INCOME. 
(a) IN GENERAL.—Section 954(a) of the Internal 
Revenue Code of 1986 is amended by striking ‘‘and’’ at 
the end of paragraph (2), by striking the period at the 
end of paragraph (3) and inserting ‘‘, and’’, and by adding 
at the end the following new paragraph: 
‘‘(4) the foreign base company oil related in-
come for the taxable year (determined under sub-
section (f) and reduced as provided in subsection 
(b)(5)).’’. 
(b) FOREIGN BASE COMPANY OIL RELATED IN-
COME.—Section 954 of the Internal Revenue Code of 1986 
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is amended by inserting after subsection (e) the following 
new subsection: 
‘‘(f) FOREIGN BASE COMPANY OIL RELATED IN-
COME.—For purposes of this section— 
‘‘(1) IN GENERAL.—Except as otherwise pro-
vided in this subsection, the term ‘foreign base com-
pany oil related income’ means foreign oil related in-
come (within the meaning of paragraphs (2) and (3) 
of section 907(c)) other than income derived from a 
source within a foreign country in connection with— 
‘‘(A) oil or gas which was extracted from 
an oil or gas well located in such foreign coun-
try, or 
‘‘(B) oil, gas, or a primary product of oil 
or gas which is sold by the foreign corporation 
or a related person for use or consumption 
within such country or is loaded in such coun-
try on a vessel or aircraft as fuel for such vessel 
or aircraft. 
Such term shall not include any foreign personal 
holding company income (as defined in subsection 
(c)). 
‘‘(2) PARAGRAPH
(1)
APPLIES
ONLY
WHERE 
CORPORATION HAS PRODUCED 1,000 BARRELS PER 
DAY OR MORE.— 
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‘‘(A) IN
GENERAL.—The term ‘foreign 
base company oil related income’ shall not in-
clude any income of a foreign corporation if 
such corporation is not a large oil producer for 
the taxable year. 
‘‘(B) LARGE
OIL
PRODUCER.—For pur-
poses of subparagraph (A), the term ‘large oil 
producer’ means any corporation if, for the tax-
able year or for the preceding taxable year, the 
average daily production of foreign crude oil 
and natural gas of the related group which in-
cludes such corporation equaled or exceeded 
1,000 barrels. 
‘‘(C) RELATED GROUP.—The term ‘related 
group’ means a group consisting of the foreign 
corporation and any other person who is a re-
lated person with respect to such corporation. 
‘‘(D) AVERAGE
DAILY
PRODUCTION
OF 
FOREIGN CRUDE OIL AND NATURAL GAS.—For 
purposes of this paragraph, the average daily 
production of foreign crude oil or natural gas of 
any related group for any taxable year (and the 
conversion of cubic feet of natural gas into bar-
rels) shall be determined under rules similar to 
the rules of section 613A (as in effect on the 
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day before the date of enactment of the End 
Polluter Welfare Act of 2024) except that only 
crude oil or natural gas from a well located out-
side the United States shall be taken into ac-
count.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 952(c)(1)(B)(iii) of the Internal 
Revenue Code of 1986 is amended by redesignating 
subclauses (I) through (IV) as subclauses (II) 
through (V), respectively, and by inserting before 
subclause (II) (as so redesignated) the following: 
‘‘(I) foreign base company oil re-
lated income,’’. 
(2) Section 954(b) of such Code is amended— 
(A) by inserting at the end of paragraph 
(4) the following: ‘‘The preceding sentence shall 
not apply to foreign base company oil-related 
income described in subsection (a)(4).’’, 
(B) by striking ‘‘and the foreign base com-
pany services income’’ in paragraph (5) and in-
serting ‘‘the foreign base company services in-
come, and the foreign base company oil related 
income’’, and 
(C) by adding at the end the following new 
paragraph: 
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‘‘(6) FOREIGN BASE COMPANY OIL RELATED IN-
COME NOT TREATED AS ANOTHER KIND OF BASE 
COMPANY INCOME.—Income of a corporation which 
is foreign base company oil related income shall not 
be considered foreign base company income of such 
corporation under paragraph (2) or (3) of subsection 
(a).’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years of foreign corpora-
tions beginning after the date of the enactment of this 
Act and to taxable years of United States shareholders 
ending with or within which such taxable years of foreign 
corporations end. 
SEC. 221. REPEAL OF EXCLUSION OF FOREIGN OIL AND 
GAS EXTRACTION INCOME FROM THE DETER-
MINATION OF TESTED INCOME. 
(a) IN GENERAL.—Section 951A(c)(2)(A)(i) of the 
Internal Revenue Code of 1986 is amended— 
(1) by adding ‘‘and’’ at the end of subclause 
(III), 
(2) by striking ‘‘and’’ at the end of subclause 
(IV) and inserting ‘‘over’’, and 
(3) by striking subclause (V). 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years of foreign corpora-
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tions beginning after the date of enactment of this Act, 
and to taxable years of United States shareholders in 
which or with which such taxable years of foreign corpora-
tions end. 
SEC. 222. TERMINATION OF CREDIT FOR CARBON OXIDE 
SEQUESTRATION. 
(a) IN GENERAL.—Section 45Q of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following: 
‘‘(j) TERMINATION.—This section shall not apply 
with respect to any qualified carbon oxide captured after 
the date of enactment of the End Polluter Welfare Act 
of 2024.’’. 
(b) REPORT.— 
(1) IN
GENERAL.—Not later than 6 months 
after the date of enactment of this Act, the Sec-
retary of the Treasury, or the Secretary’s delegate, 
shall submit a report to Congress, to be made avail-
able to the public, which provides the following infor-
mation: 
(A) The taxpayer identity information of 
any taxpayer for which the carbon oxide seques-
tration credit under section 45Q of the Internal 
Revenue Code of 1986 was allowed for any tax-
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able year following the enactment of such sec-
tion. 
(B) The total amount of the credit allowed 
pursuant to such section to each taxpayer de-
scribed in subparagraph (A). 
(C) With respect to the amount described 
in subparagraph (B), the amount of such credit 
allowed with respect to each of the following: 
(i) Qualified carbon oxide which was 
captured and disposed of by the taxpayer 
in secure geological storage and not used 
by the taxpayer as described in clause (ii) 
or (iii). 
(ii) Qualified carbon oxide which was 
captured and used by the taxpayer as a 
tertiary injectant in a qualified enhanced 
oil or natural gas recovery project and dis-
posed of by the taxpayer in secure geologi-
cal storage. 
(iii) Qualified carbon oxide which was 
captured and utilized by the taxpayer in a 
manner described in section 45Q(f)(5) of 
the Internal Revenue Code of 1986. 
(2) EXCEPTION FROM RULES REGARDING CON-
FIDENTIALITY AND DISCLOSURE OF RETURNS AND 
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RETURN INFORMATION.—Section 6103(l) of the In-
ternal Revenue Code of 1986 is amended by adding 
at the end the following: 
‘‘(23) DISCLOSURE OF RETURN INFORMATION 
FOR PUBLIC REPORT ON CARBON OXIDE SEQUES-
TRATION CREDIT.—The Secretary may disclose tax-
payer identity information and return information to 
the extent the Secretary deems necessary for pur-
poses of the report issued pursuant to section 222 
of the End Polluter Welfare Act of 2024.’’. 
SEC. 223. ELIMINATE DRAWBACKS ON PETROLEUM TAXES. 
(a) IN GENERAL.—Section 313(j) of the Tariff Act 
of 1930 (19 U.S.C. 1313(j)) is amended by adding at the 
end the following new paragraph: 
‘‘(7) No amount of any tax imposed on any merchan-
dise pursuant to section 4611 of the Internal Revenue 
Code of 1986 shall be eligible to be refunded as drawback 
under this subsection.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply with respect to articles entered, 
or withdrawn from warehouse for consumption, on or after 
January 1, 2025. 
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