‘‘(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 
‘‘(B) receives (or will receive) directly or 
indirectly a specific economic benefit (as deter-
mined in accordance with regulations) from 
such country or possession. 
‘‘(3) GENERALLY APPLICABLE INCOME TAX.— 
For purposes of this subsection— 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00020
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
‘‘(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 citizens or resi-
dents of the foreign country or posses-
sion.’’. 
(b) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendments made by 
this section shall apply to taxes paid or accrued in 
taxable years beginning after the date of the enact-
ment of this Act. 
(2) 
CONTRARY
TREATY
OBLIGATIONS 
UPHELD.—The amendments made by this section 
shall not apply to the extent contrary to any treaty 
obligation of the United States. 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00021
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
SEC. 24. INCREASE IN OIL SPILL LIABILITY TRUST FUND FI-
NANCING RATE. 
(a) IN GENERAL.—Subparagraph (B) of section 
4611(c)(2) of the Internal Revenue Code of 1986 is 
amended to read as follows: 
‘‘(B) the Oil Spill Liability Trust Fund fi-
nancing rate is— 
‘‘(i) in the case of crude oil received 
or petroleum products entered before Jan-
uary 1, 2016, 8 cents a barrel, 
‘‘(ii) in the case of crude oil received 
or petroleum products entered after De-
cember 31, 2015, and before January 1, 
2017, 9 cents a barrel, and 
‘‘(iii) in the case of crude oil received 
or petroleum products entered after De-
cember 31, 2016, 10 cents a barrel.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to crude oil received and petroleum 
products entered after the date of the enactment of this 
Act. 
SEC. 25. 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: 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00022
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
‘‘(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 any bitumen and bituminous 
mixtures, any oil manufactured from bitumen 
and bituminous mixtures, and any liquid fuel 
manufactured from coal.’’. 
(b) EFFECTIVE DATE.—The amendment 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. 26. DENIAL OF DEDUCTION FOR REMOVAL COSTS AND 
DAMAGES FOR CERTAIN OIL SPILLS. 
(a) IN GENERAL.—Part IX of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by adding at the end the following new section: 
‘‘SEC. 280I. EXPENSES FOR REMOVAL COSTS AND DAMAGES 
RELATING TO CERTAIN OIL SPILL LIABILITY. 
‘‘No deduction shall be allowed under this chapter for 
any amount paid or incurred with respect to 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).’’. 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00023
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
(b) CLERICAL AMENDMENT.—The table of sections 
for part IX of subchapter B of chapter 1 of such Code 
is amended by adding at the end the following new item: 
‘‘Sec. 280I. Expenses for removal costs and damages relating to certain oil spill 
liability.’’. 
(c) 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. 27. TAX ON CRUDE OIL AND NATURAL GAS PRODUCED 
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 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00024
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
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 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00025
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
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. 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00026
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
‘‘(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 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00027
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
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. 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00028
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
‘‘(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, 2015. 
SEC. 28. REPEAL OF CORPORATE INCOME TAX EXEMPTION 
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— 
(1) by striking subparagraph (E), 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00029
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS
(2) by redesignating subparagraphs (F) and 
(G) as subparagraphs (E) and (F), respectively, and 
(3) by striking the flush matter at the end. 
(b) 
CONFORMING
AMENDMENT.—Section 
988(c)(1)(E)(iii)(III) of the Internal Revenue Code of 
1986 is amended by striking ‘‘or (G)’’ and inserting ‘‘or 
(F)’’. 
(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. 29. POWDER RIVER BASIN. 
(a) DESIGNATION OF THE POWDER RIVER BASIN AS 
A COAL PRODUCING REGION.—The Director of the Bu-
reau of Land Management shall designate the Powder 
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 of royalties paid on coal leases in the Pow-
der River Basin compared to other national and 
international coal markets; and 
VerDate Sep 11 2014 
23:38 May 04, 2015
Jkt 049200
PO 00000
Frm 00030
Fmt 6652
Sfmt 6201
E:\BILLS\H1930.IH
H1930
SSpencer on DSK4SPTVN1PROD with BILLS