In this task, you are given text for US Congressional and California state bills, your task is to generate a summary for this bill.

Ex Input:
SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Childrens' Media Protection Act of 
1995''.

SEC. 2. FINDINGS.

    Congress makes the following findings:
            (1) On average, a child in the United States is exposed to 
        27 hours of television each week, and some children are exposed 
        to as much as 11 hours of television each day.
            (2) The average American child watches 8,000 murders and 
        100,000 acts of other violence on television by the time the 
        child completes elementary school.
            (3) By the age of 18 years, the average American teenager 
        has watched 200,000 acts of violence on television, including 
        40,000 murders.
            (4) The Times Mirror Center reports that a recent poll of 
        Americans indicates that 72 percent of the American people 
        believe that there is too much violence on television, and, 
        according to a survey by U.S. News and World Report dated May 
        1994, 91 percent of American voters believe that mayhem in the 
        media contributes to violence in real life.
            (5) On several occasions since 1975, The Journal of the 
        American Medical Association has alerted the medical community 
        to the adverse effects of televised violence on child 
        development, including an increase in the level of aggressive 
        behavior and violent behavior among children who view it.
            (6) The National Commission on Children recommended in 1991 
        that producers of television programs exercise greater 
        restraint in the content of programming for children.
            (7) A report of the Harry Frank Guggenheim Foundation, 
        dated May 1993, indicates that there is an irrefutable 
        connection between the amount of violence depicted in the 
        television programs watched by children and increased 
        aggressive behavior among children.
            (8) It is in the National interest that parents be 
        empowered with the technology to block the viewing of 
        television programs whose content is overly violent or 
        objectionable for other reasons.
            (9) Technology currently exists to permit the manufacture 
        of television receivers that are capable of permitting parents 
        to block television programs having violent or otherwise 
        objectionable content.

SEC. 3. ESTABLISHMENT OF TELEVISION VIOLENCE RATING CODE.

    Section 303 of the Communications Act of 1934 (47 U.S.C. 303) is 
amended by adding at the end the following:
    ``(v) Prescribe, in consultation with television broadcasters, 
cable operators, appropriate public interest groups, and interested 
individuals from the private sector, rules for rating the level of 
violence in television programming, including rules for the 
transmission by television broadcast systems and cable systems of 
signals containing specifications for blocking violent programming.''.

SEC. 4. REQUIREMENT FOR MANUFACTURE OF TELEVISIONS THAT BLOCK PROGRAMS.

    Section 303 of the Communications Act of 1934 (47 U.S.C. 303), as 
amended by section 3, is further amended by adding at the end the 
following:
    ``(w) Require, in the case of apparatus designed to receive 
television signals that are manufactured in the United States or 
imported for use in the United States and that have a picture screen 13 
inches or greater in size (measured diagonally), that such apparatus--
            ``(1) be equipped with circuitry designed to enable viewers 
        to block the display of channels, programs, and time slots; and
            ``(2) enable viewers to block display of all programs with 
        a common rating.''.

SEC. 5. SHIPPING OR IMPORTING OF TELEVISIONS THAT BLOCK PROGRAMS.

    (a) Regulations.--Section 330 of the Communications Act of 1934 (47 
U.S.C. 330) is amended--
            (1) by redesignating subsection (c) as subsection (d); and
            (2) by adding after subsection (b) the following new 
        subsection (c):
    ``(c)(1) Except as provided in paragraph (2), no person shall ship 
in interstate commerce, manufacture, assemble, or import from any 
foreign country into the United States any apparatus described in 
section 303(w) of this Act except in accordance with rules prescribed 
by the Commission pursuant to the authority granted by that section.
    ``(2) This subsection shall not apply to carriers transporting 
apparatus referred to in paragraph (1) without trading it.
    ``(3) The rules prescribed by the Commission under this subsection 
shall provide performance standards for blocking technology. Such rules 
shall require that all such apparatus be able to receive the rating 
signals which have been transmitted by way of line 21 of the vertical 
blanking interval and which conform to the signal and blocking 
specifications established by the Commission.
    ``(4) As new video technology is developed, the Commission shall 
take such action as the Commission determines appropriate to ensure 
that blocking service continues to be available to consumers.''.
    (b) Conforming Amendment.--Section 330(d) of such Act, as 
redesignated by subsection (a)(1), is amended by striking ``section 
303(s), and section 303(u)'' and inserting in lieu thereof ``and 
sections 303(s), 303(u), and 303(w)''.

SEC. 6. ELIMINATION OF VIOLENT PROGRAMMING ON TELEVISION DURING CERTAIN 
              HOURS.

    Title I of the Children's Television Act of 1990 (47 U.S.C. 303a et 
seq.) is amended by adding at the end the following:

                  ``prohibition on violent programming

    ``Sec. 105. (a) The Commission shall, within 30 days of the date of 
the enactment of this Act, initiate a rule-making proceeding to 
prescribe a prohibition on the broadcast on commercial television and 
by public telecommunications entities, including the broadcast by cable 
operators, from the hours of 6 a.m. to 10 p.m., inclusive, of 
programming that contains gratuitous violence.
    ``(b) As used in this section:
            ``(1) The term `cable operator' has the meaning given such 
        term in section 602 of the Communications Act of 1934 (47 
        U.S.C. 522).
            ``(2) The term `programming' includes advertisements but 
        does not include bona fide newscasts, bona fide news 
        interviews, bona fide news documentaries, and on-the-spot 
        coverage of bona fide news events.
            ``(3) The term `public telecommunications entity' has the 
        meaning given such term in section 397(12) of the 
        Communications Act of 1934 (47 U.S.C. 397(12)).''.

SEC. 7. BROADCAST ON TELEVISION AND CABLE OF EDUCATIONAL AND 
              INFORMATIONAL PROGRAMMING FOR CHILDREN.

    (a) Broadcast Television.--Section 309 of the Communications Act of 
1934 (47 U.S.C. 309) is amended by adding at the end the following:
    ``(k) Educational and Information Programming for Children.--In 
granting an application for a license for a television broadcasting 
station (including an application for renewal of such a license), the 
Commission shall impose such conditions upon the applicant as the 
Commission requires in order to ensure that the applicant complies 
under the license with the standards for children's television 
programming established under section 102 of the Children's Television 
Act of 1990 (47 U.S.C. 303a) and otherwise serves the educational and 
informational needs of children through its overall programming.''.
    (b) Cable Service.--Part III of title VI of the Communications Act 
of 1934 (47 U.S.C. 541 et seq.) is amended by adding at the end the 
following:

         ``educational and information programming for children

    ``Sec. 629. A franchise, including the renewal of a franchise, may 
not be awarded under this part unless the cable operator to be awarded 
the franchise agrees to comply with the standards for children's 
television programming established under section 102 of the Children's 
Television Act of 1990 (47 U.S.C. 303a) and to otherwise serve the 
educational and informational needs of children in the provision of 
cable service under the franchise.''.

Ex Output:
Childrens' Media Protection Act of 1995 - Amends the Communications Act of 1934 to direct the Federal Communications Commission (FCC) to: (1)  prescribe rules for the rating of violence levels in television programming, including rules for the transmission of signals containing specifications for blocking violent programming; and (2) require television sets with picture screens of 13 inches or more to be equipped with blocking circuitry and enable viewers to block display of all programs with a common rating.  Prohibits any person from shipping, manufacturing, assembling, or importing any television not so equipped.  Requires performance standards for blocking technology. 
(Sec. 6) Directs the FCC to initiate a rulemaking proceeding to prescribe a prohibition on the broadcast on commercial television and any public telecommunications entities between six o'clock a.m. and ten o'clock p.m., inclusively, of programming that contains gratuitous violence. 
(Sec. 7) Directs the FCC, in granting an application for a television broadcast license, to impose conditions which ensure that the applicant complies with the standards for children's television programming as established under the Children's Television Act of 1990 and otherwise serves the educational and informational needs of children through its overall programming.  Prohibits a cable franchise award or renewal unless the cable operator complies with such standards.


Ex Input:
SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Mandatory Foreclosure Mediation 
Act''.

SEC. 2. DEFINITIONS.

    In this Act, the following definitions shall apply:
            (1) Alternative to foreclosure.--The term ``alternative to 
        foreclosure''--
                    (A) means a course of action with respect to a 
                mortgage offered by a servicer to a borrower as an 
                alternative to a covered foreclosure action; and
                    (B) includes a short sale and a deed in lieu of 
                foreclosure.
            (2) Borrower.--The term ``borrower'' means a mortgagor 
        under a mortgage who is in default or at risk of imminent 
        default, as determined by the Secretary through regulations.
            (3) Foreclosure action.--The term ``foreclosure action'' 
        means a judicial or nonjudicial foreclosure.
            (4) Loan modification program.--The term ``loan 
        modification program'' means a program or procedure designed to 
        change the terms of a mortgage in the case of the default, 
        delinquency, or imminent default or delinquency of a mortgagor, 
        including a loan modification program established by a servicer 
        that reduces the principal owed by the mortgagor on the 
        mortgage.
            (5) Mortgage.--The term ``mortgage'' means a federally 
        related mortgage loan, as defined in section 3(1) of the Real 
        Estate Settlement Procedures Act of 1974 (12 U.S.C. 2602(1)), 
        that is secured by a first or subordinate lien on residential 
        real property.
            (6) Secretary.--The term ``Secretary'' means the Secretary 
        of Housing and Urban Development.
            (7) Servicer.--The term ``servicer''--
                    (A) has the same meaning as in section 6(i) of the 
                Real Estate Settlement Procedures Act of 1974 (12 
                U.S.C. 2605(i)); and
                    (B) includes a person responsible for servicing a 
                pool of mortgages.

SEC. 3. MEDIATION REQUIRED BEFORE FORECLOSURE.

    (a) Initiation of Foreclosure Actions.--A servicer may not initiate 
a foreclosure action against a borrower unless the servicer has--
            (1) made a reasonable effort to initiate mediation 
        proceedings in accordance with the process established in 
        regulations prescribed pursuant to subsection (c) to determine 
        whether the borrower is eligible for a loan modification or an 
        alternative to foreclosure; and
            (2) offered the borrower a loan modification or an 
        alternative to foreclosure, if the borrower is eligible for the 
        loan modification or alternative to foreclosure.
    (b) Suspension of Foreclosure Actions.--
            (1) In general.--A servicer shall suspend a foreclosure 
        action that was initiated before the date of enactment of this 
        Act until the servicer--
                    (A) completes a mediation proceeding in accordance 
                with the process established in regulations prescribed 
                pursuant to subsection (c) to determine whether the 
                borrower is eligible for a loan modification or an 
                alternative to foreclosure; and
                    (B) offers the borrower a loan modification or an 
                alternative to foreclosure, if the borrower is eligible 
                for a loan modification or an alternative to 
                foreclosure.
            (2) Suspension.--During the period of the suspension under 
        paragraph (1), a servicer may not--
                    (A) send a notice of foreclosure to a borrower;
                    (B) conduct or schedule a sale of the real property 
                securing the mortgage of the borrower; or
                    (C) cause final judgment to be entered against the 
                borrower.
            (3) Reasonable efforts.--A servicer is not required to 
        suspend a foreclosure action under paragraph (1) if the 
        servicer--
                    (A) makes a reasonable effort to schedule a 
                mediation proceeding to determine whether the borrower 
                is eligible for a loan modification or an alternative 
                to foreclosure; and
                    (B) documents that the borrower has not agreed to a 
                mediation proceeding to determine whether the borrower 
                is eligible for a loan modification or an alternative 
                to foreclosure.
            (4) Rule of construction.--Nothing in this section may be 
        construed to require a servicer to delay an unavoidable 
        foreclosure, such as foreclosure that results from a borrower 
        abandoning the residential real property securing a mortgage.
    (c) Establishment of Mediation Process.--The Secretary shall 
establish through regulations a mediation process to determine whether 
the borrower is eligible for a loan modification or an alternative to 
foreclosure under this section.

SEC. 4. BAR TO FORECLOSURE ACTIONS.

    (a) In General.--Subject to subsection (b), a violation of this Act 
shall be a bar to a foreclosure action.
    (b) Effect of Subsequent Compliance.--If a servicer is in 
compliance with this Act, the servicer may bring or proceed with a 
foreclosure action, without regard to a prior violation of this Act by 
the servicer.

SEC. 5. REGULATIONS.

    Not later than 90 days after the date of enactment of this Act, the 
Secretary shall issue regulations to carry out this Act.

SEC. 6. REPORT.

    Each servicer that initiates mediation proceedings under section 3 
shall submit to the Secretary a quarterly report at such time, in such 
manner, and containing such information, with respect to such 
proceedings, as the Secretary may require.

Ex Output:
Mandatory Foreclosure Mediation Act - Prohibits a servicer from initiating a foreclosure action against a borrower unless the servicer has: (1) made a reasonable effort to initiate mediation proceedings to determine if the borrower is eligible for a loan modification or an alternative to foreclosure; and (2) offered the borrower, if eligible, such a modification or alternative.

Requires a servicer to suspend a foreclosure action initiated before the enactment of this Act until the servicer: (1) completes such a mediation proceeding; and (2) offers the borrower, if eligible, a modification or alternative.

Prohibits a servicer, during the suspension period, from: (1) sending the borrower a notice of foreclosure, (2) conducting or scheduling a sale of the real property securing the mortgage, or (3) causing final judgment to be entered against the borrower.

Directs the Secretary of Housing and Urban Development (HUD) to establish such a mediation process.

Declares that a servicer is not required to suspend a foreclosure action if the servicer makes a reasonable effort to schedule a mediation proceeding and documents that the borrower has not agreed to one.

Makes a violation of this Act a bar to a foreclosure action. Allows a servicer in compliance with this Act, however, to bring or proceed with a foreclosure action, regardless of any prior violation.


Ex Input:
SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Close Big Oil Tax Loopholes Act''.

SEC. 2. LIMITATION ON DEDUCTION FOR INTANGIBLE DRILLING AND DEVELOPMENT 
              COSTS.

    (a) In General.--Section 263(c) of the Internal Revenue Code of 
1986 is amended by adding at the end the following new sentence: ``This 
subsection shall not apply to amounts paid or incurred by a taxpayer in 
any taxable year in which such taxpayer is an applicable large taxpayer 
(as defined in section 193(d)(2)).''.
    (b) Effective Date.--The amendment made by this section shall apply 
to amounts paid or incurred in taxable years beginning after December 
31, 2010.

SEC. 3. LIMITATION ON DEDUCTION FOR TERTIARY INJECTANTS.

    (a) In General.--Section 193 of the Internal Revenue Code of 1986 
is amended by adding at the end the following new subsection:
    ``(d) Application With Respect to Certain Large Taxpayers.--
            ``(1) In general.--This section shall not apply to amounts 
        paid or incurred by a taxpayer in any taxable year in which 
        such taxpayer is an applicable large taxpayer.
            ``(2) Applicable large taxpayer.--For purposes of this 
        section, the term `applicable large taxpayer' means, with 
        respect to any taxable year, any taxpayer with gross revenues 
        for such taxable year in excess of $100,000,000.''.
    (b) Effective Date.--The amendment made by this section shall apply 
to amounts paid or incurred in taxable years beginning after December 
31, 2010.

SEC. 4. LIMITATION ON EXCEPTION FROM PASSIVE ACTIVITY RULES FOR WORKING 
              INTERESTS IN OIL OR GAS PROPERTY.

    (a) In General.--Paragraph (3) of section 469(c) of the Internal 
Revenue Code of 1986 is amended--
            (1) in subparagraph (A), by striking ``the taxpayer'' and 
        inserting ``a taxpayer (other than an a taxpayer who is an 
        applicable large taxpayer (as defined in section 193(d)(2)) for 
        the taxable year)'', and
            (2) in subparagraph (B), by inserting ``other than an a 
        taxpayer who is an applicable large taxpayer (as so defined) 
        for the taxable year'' after ``any taxpayer''.
    (b) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2010.

SEC. 5. LIMITATION ON PERCENTAGE DEPLETION ALLOWANCE FOR OIL AND GAS 
              WELLS.

    (a) In General.--Section 613A of the Internal Revenue Code of 1986 
is amended by adding at the end the following new subsection:
    ``(f) Application With Respect to Certain Large Taxpayers.--In the 
case of any taxable year in which the taxpayer is an applicable large 
taxpayer (as defined in section 193(d)(2)), the allowance for 
percentage depletion shall be zero.''.
    (b) Effective Date.--The amendment made by this section shall apply 
to taxable years beginning after December 31, 2010.

SEC. 6. LIMITATION ON DEDUCTION FOR INCOME ATTRIBUTABLE TO DOMESTIC 
              PRODUCTION OF OIL, NATURAL GAS, OR PRIMARY PRODUCTS 
              THEREOF.

    (a) Denial of Deduction.--Paragraph (4) of section 199(c) of the 
Internal Revenue Code of 1986 is amended by adding at the end the 
following new subparagraph:
                    ``(E) Special rule for certain oil and gas 
                income.--In the case of any taxpayer who is an 
                applicable large taxpayer (as defined in section 
                193(d)(2)) for the taxable year, the term `domestic 
                production gross receipts' shall not include gross 
                receipts from the production, transportation, or 
                distribution of oil, natural gas, or any primary 
                product (within the meaning of subsection (d)(9)) 
                thereof.''.
    (b) Effective Date.--The amendment made by this section shall apply 
to taxable years beginning after December 31, 2010.

SEC. 7. EXPANSION OF 7-YEAR AMORTIZATION OF GEOLOGICAL AND GEOPHYSICAL 
              EXPENDITURES TO APPLICABLE LARGE TAXPAYERS.

    (a) In General.--Subparagraph (A) of section 167(h)(5) of the 
Internal Revenue Code of 1986 is amended by inserting ``or an 
applicable large taxpayer (as defined in section 193(d)(2))'' after 
``major integrated oil company''.
    (b) Conforming Amendment.--The heading for paragraph (5) of section 
167(h) of such Code is amended by inserting ``and applicable large 
taxpayers'' after ``oil companies''.
    (c) Effective Date.--The amendments made by this section shall 
apply to amounts paid or incurred in taxable years beginning after 
December 31, 2010.

SEC. 8. 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 Revenue Code of 1986 
(relating to alcohol, tobacco, and certain other excise taxes) 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. 5896. Imposition of tax.
``Sec. 5897. Taxable crude oil or natural gas and removal price.
``Sec. 5898. Special rules and definitions.

``SEC. 5896. IMPOSITION OF TAX.

    ``(a) In General.--In addition to any other tax imposed under this 
title, there is hereby imposed a tax equal to 13 percent of the removal 
price of any taxable crude 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 respect 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 period.
    ``(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. 5897. TAXABLE CRUDE OIL OR NATURAL GAS AND REMOVAL 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 produced from Federal submerged lands on the outer 
Continental Shelf in the Gulf of Mexico pursuant to a lease entered 
into with the United States which authorizes the production.
    ``(b) Removal Price.--For purposes of this chapter--
            ``(1) In general.--Except as otherwise provided 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 removal 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 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.
            ``(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 begins, and
                    ``(B) the removal price shall be the constructive 
                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. 5898. 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 5896 on a quarterly basis.
            ``(2) Records and information.--Each taxpayer liable for 
        tax under section 5896 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 gas) with respect to such oil as the Secretary may by 
        regulations prescribe.
            ``(3) Taxable periods; return of tax.--
                    ``(A) Taxable period.--Except as provided by the 
                Secretary, each calendar year shall constitute a 
                taxable period.
                    ``(B) Returns.--The Secretary shall provide for the 
                filing, and the time for filing, of the return of the 
                tax imposed under section 5896.
    ``(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 determining gross income from the property under 
        section 613.
    ``(c) Adjustment of Removal Price.--In determining the removal 
price of oil or natural gas from a property in the case of any 
transaction, the Secretary may adjust the removal price to reflect 
clearly the fair market value of oil or natural gas removed.
    ``(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 (relating to deduction for taxes) is 
amended by inserting after paragraph (5) the following new paragraph:
            ``(6) The tax imposed by section 5896(a) (after application 
        of section 5896(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 of 
such Code is amended by adding at the end the following 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 the date of the 
enactment of this Act.

SEC. 9. MODIFICATIONS OF FOREIGN TAX CREDIT RULES APPLICABLE TO LARGE 
              INTEGRATED OIL COMPANIES WHICH ARE DUAL CAPACITY 
              TAXPAYERS.

    (a) In General.--Section 901 of the Internal Revenue Code of 1986 
(relating to credit for taxes of foreign countries and of possessions 
of the United States) is amended by redesignating subsection (m) as 
subsection (n) and by inserting after subsection (l) the following new 
subsection:
    ``(m) Special Rules Relating to Large Integrated Oil Companies 
Which Are Dual Capacity Taxpayers.--
            ``(1) General rule.--Notwithstanding any other provision of 
        this chapter, any amount paid or accrued by a dual capacity 
        taxpayer which is a large integrated oil company to a foreign 
        country or possession of the United States for any period shall 
        not be considered a tax--
                    ``(A) if, for such period, the foreign country or 
                possession does not impose a generally applicable 
                income tax, or
                    ``(B) to the extent such amount exceeds the amount 
                (determined in accordance with regulations) which--
                            ``(i) is paid by such dual capacity 
                        taxpayer pursuant to the generally applicable 
                        income tax imposed by the country or 
                        possession, or
                            ``(ii) would be paid if the generally 
                        applicable 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 subparagraph (B).
            ``(2) Dual capacity taxpayer.--For purposes of this 
        subsection, the term `dual capacity taxpayer' 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 determined 
                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 imposed 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 application, by its terms 
                and in practice, to--
                            ``(i) persons who are not dual capacity 
                        taxpayers, and
                            ``(ii) persons who are citizens or 
                        residents of the foreign country or possession.
            ``(4) Large integrated oil company.--For purposes of this 
        subsection, the term `large integrated oil company' means, with 
        respect to any taxable year, an integrated oil company (as 
        defined in section 291(b)(4)) which--
                    ``(A) had gross receipts in excess of 
                $1,000,000,000 for such taxable year, and
                    ``(B) has an average daily worldwide production of 
                crude oil of at least 500,000 barrels for such taxable 
                year.''.
    (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 enactment 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.

Ex Output:

Close Big Oil Tax Loopholes Act - Amends the Internal Revenue Code to deny to taxpayers with gross revenues in excess of $100 million in a taxable year (applicable large taxpayers): (1) the tax deduction for intangible drilling and development costs; (2) the tax deduction for qualified tertiary injectant expenses; (3) the exemption from restrictions on the deductibility of passive losses; (4) the percentage depletion allowance for oil and gas wells; and (5) the tax deduction for income attributable to domestic production of oil, natural gas, or primary products thereof.

Requires applicable large taxpayers to amortize their geological and geophysical expenditures over a seven-year period.

Imposes on producers of taxable crude oil or natural gas a 13% excise tax on the removal price of such oil and natural gas produced from lands on the Outer Continental Shelf in the Gulf of Mexico. Allows a nonrefundable credit against such tax for royalties paid under federal law with respect to the production of such crude oil and natural gas.

Denies a foreign tax credit to any large integrated oil company that is subject to a levy of a foreign country or possession of the United States and receives an economic benefit from such country or possession (dual capacity taxpayer) if such country or possession does not impose a generally applicable income tax.