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SECTION 1. SHORT TITLE.

This Act may be cited as the ''Medical Device Tax Elimination
Act''.

SEC. 2. REPEAL OF MEDICAL DEVICE EXCISE TAX.

(a) In General.--Chapter 32 of the Internal Revenue Code of 1986 is
amended by striking subchapter E.
(b) Conforming Amendments.--
(1) Section 4221(a) of such Code is amended by striking the
last sentence.
(2) Section 6416(b)(2) of such Code is amended by striking
the last sentence.
(c) Clerical Amendment.--The table of subchapters for chapter 32 of
such Code is amended by striking the item relating to subchapter E.
(d) Effective Date.--The amendments made by this section shall
apply to sales after the date of the enactment of this Act.

SEC. 3. LIMITATION ON SECTION 199 DEDUCTION ATTRIBUTABLE TO OIL,
NATURAL GAS, OR PRIMARY PRODUCTS THEREOF.

(a) Denial of Deduction.--Section 199(c)(4) 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 a major
integrated oil company (as defined in section
167(h)(5)(B)) 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, 2014.

SEC. 4. PROHIBITION ON USING LAST-IN, FIRST-OUT ACCOUNTING FOR MAJOR
INTEGRATED OIL COMPANIES.

(a) In General.--Section 472 of the Internal Revenue Code of 1986
is amended by adding at the end the following new subsection:
''(h) Major Integrated Oil Companies.--Notwithstanding any other
provision of this section, a major integrated oil company (as defined
in section 167(h)(5)(B)) may not use the method provided in subsection
(b) in inventorying of any goods.''.
(b) Effective Date and Special Rule.--
(1) In general.--The amendment made by subsection (a) shall
apply to taxable years beginning after December 31, 2014.
(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 accounting for its first taxable year
beginning after December 31, 2014--
(A) such change shall be treated as initiated by
the taxpayer,
(B) such change shall be treated as made with the
consent of the Secretary of the Treasury, and
(C) the net amount of the adjustments required 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) beginning with such first taxable year.

SEC. 5. MODIFICATIONS OF FOREIGN TAX CREDIT RULES APPLICABLE TO MAJOR
INTEGRATED OIL COMPANIES WHICH ARE DUAL CAPACITY
TAXPAYERS.

(a) In General.--Section 901 of the Internal Revenue 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 Major 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 major integrated oil company (as defined in
section 167(h)(5)(B)) 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.''.
(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, 2014.
(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.
Medical Device Tax Elimination Act This bill amends the Internal Revenue Code to repeal the excise tax on medical devices and offsets the cost of such repeal by: (1) eliminating the tax deduction for income attributable to oil, natural gas, or primary products thereof for major integrated oil companies (companies that have an average daily worldwide annual production of crude oil of at least 500,000 barrels and annual gross receipts in excess of $1 billion); (2) prohibiting the use of the last-in, first-out (LIFO) accounting method by major integrated oil companies; and (3) denying the foreign tax credit to major integrated oil companies that are dual taxpayers (companies that receive an economic benefit from a foreign country or a possession of the United States that does not impose a generally applicable income tax).