I 
117TH CONGRESS 
1ST SESSION H. R. 2291 
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 
MARCH 29, 2021 
Mr. THOMPSON of California (for himself and Mr. ESTES) introduced the 
following bill; which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to 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 ‘‘Financing Our Energy 
Future Act’’. 
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SEC. 2. GREEN ENERGY PUBLICLY TRADED PARTNER-
SHIPS. 
(a) IN GENERAL.—Section 7704(d)(1)(E) of the In-
ternal Revenue Code of 1986 is amended— 
(1) by striking ‘‘income and gains derived from 
the exploration’’ and inserting ‘‘income and gains 
derived from— 
‘‘(i) the exploration’’; 
(2) 
by 
inserting 
‘‘or’’ 
before 
‘‘industrial 
source’’; and 
(3) by striking ‘‘, or the transportation or stor-
age’’ and all that follows and inserting the following: 
‘‘(ii) the generation of electric power 
or thermal energy exclusively using any 
qualified energy resource (as defined in 
section 45(c)(1)), 
‘‘(iii) the operation of energy property 
(as defined in section 48(a)(3), determined 
without regard to any date by which the 
construction of the facility is required to 
begin), 
‘‘(iv) in the case of a facility described 
in paragraph (3) or (7) of section 45(d) 
(determined without regard to any placed 
in service date or date by which construc-
tion of the facility is required to begin), 
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the accepting or processing of open-loop 
biomass or municipal solid waste, 
‘‘(v) the storage of electric power or 
thermal energy exclusively using energy 
property that is energy storage property 
(as defined in section 48(c)(5)), 
‘‘(vi) the generation, storage, or dis-
tribution of electric power or thermal en-
ergy exclusively using energy property that 
is combined heat and power system prop-
erty (as defined in section 48(c)(3), deter-
mined without regard to subparagraph 
(B)(iii) thereof and without regard to any 
date by which the construction of the facil-
ity is required to begin), 
‘‘(vii) the transportation or storage of 
any fuel described in subsection (b), (c), 
(d), or (e) of section 6426, 
‘‘(viii) the conversion of renewable bio-
mass (as defined in subparagraph (I) of 
section 211(o)(1) of the Clean Air Act (as 
in effect on the date of the enactment of 
this clause)) into renewable fuel (as de-
fined in subparagraph (J) of such section 
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as so in effect), or the storage or transpor-
tation of such fuel, 
‘‘(ix) the production, storage, or 
transportation of any fuel which— 
‘‘(I) uses as its primary feedstock 
carbon oxides captured from an an-
thropogenic source or the atmosphere, 
‘‘(II) does not use as its primary 
feedstock carbon oxide which is delib-
erately released from naturally occur-
ring subsurface springs, and 
‘‘(III) is determined by the Sec-
retary, after consultation with the 
Secretary of Energy and the Adminis-
trator of the Environmental Protec-
tion Agency, to achieve a reduction of 
not less than a 60 percent in lifecycle 
greenhouse gas emissions (as defined 
in section 211(o)(1)(H) of the Clean 
Air Act, as in effect on the date of the 
enactment of this clause) compared to 
baseline lifecycle greenhouse gas emis-
sions 
(as 
defined 
in 
section 
211(o)(1)(C) of such Act, as so in ef-
fect), 
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‘‘(x) the generation of electric power 
from, a qualifying gasification project (as 
defined in section 48B(c)(1) without re-
gard to subparagraph (C)) that is de-
scribed in section 48(d)(1)(B), 
‘‘(xi) in the case of a qualified facility 
(as defined in section 45Q(d), without re-
gard to any date by which construction of 
the facility is required to begin) not less 
than 50 percent (30 percent in the case of 
a facility placed in service before January 
1, 2022) of the total carbon oxide produc-
tion of which is qualified carbon oxide (as 
defined in section 45Q(c))— 
‘‘(I) the generation, availability 
for such generation, or storage of elec-
tric power at such facility, or 
‘‘(II) the capture of carbon diox-
ide by such facility, or 
‘‘(xii) the production, storage, or 
transportation of any renewable chemical 
which— 
‘‘(I) is produced in the United 
States (or in a territory or possession 
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