‘‘(III) with respect to an estate 
or trust, 15 percent or more of the 
beneficial interests in such estate or 
trust. 
For purposes of determining a significant 
ownership interest, an interest owned by or 
for a corporation, partnership, trust, or es-
tate shall be considered as owned directly 
both by itself and proportionately by its 
shareholders, partners, or beneficiaries, as 
the case may be.’’. 
(b) EFFECTIVE DATE AND SPECIAL RULE.— 
(1) IN
GENERAL.—The amendment made by 
subsection (a) shall apply to taxable years beginning 
after December 31, 2022. 
(2) CHANGE IN METHOD OF ACCOUNTING.—In 
the case of any taxpayer required by the amendment 
made by this section to change its method of ac-
counting for its first taxable year beginning after the 
date of the enactment of this Act— 
(A) such change shall be treated as initi-
ated by the taxpayer, 
(B) such change shall be treated as made 
with the consent of the Secretary of the Treas-
ury, and 
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(C) the net amount of the adjustments re-
quired to be taken into account by the taxpayer 
under section 481 of the Internal Revenue Code 
of 1986 shall be taken into account ratably over 
a period (not greater than 8 taxable years) be-
ginning with such first taxable year. 
SEC. 11. MODIFICATIONS OF FOREIGN TAX CREDIT RULES 
APPLICABLE TO 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 DUAL CAPACITY 
TAXPAYERS.— 
‘‘(1) GENERAL
RULE.—Notwithstanding any 
other provision of this chapter, any amount paid or 
accrued by a dual capacity taxpayer to a foreign 
country or possession of the United States for any 
period with respect to combined foreign oil and gas 
income (as defined in section 907(b)(1)) shall not be 
considered a tax to the extent such amount exceeds 
the amount (determined in accordance with regula-
tions) which would have been required to be paid if 
the taxpayer were not a dual capacity taxpayer. 
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‘‘(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.’’. 
(b) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendments made by 
this section shall apply to taxes paid or accrued in 
taxable years beginning after December 31, 2022. 
(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. 
SEC. 12. CLARIFICATION OF TAR SANDS AS CRUDE OIL FOR 
EXCISE TAX PURPOSES. 
(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.—The term ‘crude oil’ includes 
crude oil condensates, natural gasoline, any bitumen 
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or bituminous mixture, any oil derived from a bitu-
men or bituminous mixture (including oil derived 
from tar sands), and 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 such Code is amended 
by adding at the end the following new paragraph: 
‘‘(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— 
‘‘(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 
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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 such Code is amended by striking ‘‘from 
a well located’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
Æ 
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