End Welfare for Big Oil Act of 2013 - Amends the Internal Revenue Code to limit or repeal certain tax benefits for major integrated oil companies (defined as companies with annual gross receipts over $1 billion and an average daily worldwide production of crude oil of at least 500,000 barrels or certain successors in interest of such companies), including: (1) the foreign tax credit for companies that are dual capacity taxpayers; (2) the tax deduction for income attributable to the production, transportation, or distribution of oil, natural gas, or primary products thereof; (3) the tax deduction for intangible drilling and development costs; (4) the percentage depletion allowance for oil and gas wells; and (5) the tax deduction for qualified tertiary injectant expenses.
Amends the Energy Policy Act of 2005 to repeal royalty relief (suspension of royalties) for: (1) natural gas production from deep wells in shallow waters of the Gulf of Mexico; and (2) deep water oil and gas production in the Western and Central Planning Area of the Gulf (including the portion of the Eastern Planning Area encompassing whole lease blocks lying west of 87 degrees, 30 minutes west longitude).
Dedicates any increased revenue generated by this Act to the reduction of a federal budget deficit or the federal debt.
[Congressional Bills 113th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2956 Introduced in House (IH)]
113th CONGRESS
1st Session
H. R. 2956
To eliminate unnecessary oil tax credits and subsidies for major oil
companies to reduce the national debt.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
August 1, 2013
Mr. Murphy of Florida (for himself, Mr. Blumenauer, Ms. Esty, and Mr.
Barber) introduced the following bill; which was referred to the
Committee on Ways and Means, and in addition to the Committee on
Natural Resources, for a period to be subsequently determined by the
Speaker, in each case for consideration of such provisions as fall
within the jurisdiction of the committee concerned
_______________________________________________________________________
A BILL
To eliminate unnecessary oil tax credits and subsidies for major oil
companies to reduce the national debt.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``End Welfare for Big Oil Act of
2013''.
TITLE I--REPEAL OF OIL AND GAS SUBSIDIES
Subtitle A--Close Big Oil Tax Loopholes
SEC. 101. 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
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.
SEC. 102. LIMITATION ON SECTION 199 DEDUCTION ATTRIBUTABLE TO 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 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, 2013.
SEC. 103. 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 a major integrated oil
company (as defined in section 167(h)(5)(B)).''.
(b) Effective Date.--The amendment made by this section shall apply
to amounts paid or incurred in taxable years beginning after December
31, 2013.
SEC. 104. 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 Major Integrated Oil Companies.--
In the case of any taxable year in which the taxpayer is a major
integrated oil company (as defined in section 167(h)(5)(B)), 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, 2013.
SEC. 105. 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 Major Integrated Oil Companies.--
This section shall not apply to amounts paid or incurred by a taxpayer
in any taxable year in which such taxpayer is a major integrated oil
company (as defined in section 167(h)(5)(B)).''.
(b) Effective Date.--The amendment made by this section shall apply
to amounts paid or incurred in taxable years beginning after December
31, 2013.
Subtitle B--Outer Continental Shelf Oil and Natural Gas
SEC. 111. REPEAL OF OUTER CONTINENTAL SHELF DEEP WATER AND DEEP GAS
ROYALTY RELIEF.
(a) In General.--Sections 344 and 345 of the Energy Policy Act of
2005 (42 U.S.C. 15904, 15905) are repealed.
(b) Limitation on Application.--The repeal under subsection (a)
shall not affect the application of the repealed sections with respect
to any lease sale for which a notice of sale is published before the
date of enactment of this Act.
TITLE II--BUDGETARY EFFECTS
SEC. 201. DEFICIT REDUCTION.
The net amount of any savings realized as a result of the enactment
of this Act and the amendments made by this Act (after any expenditures
authorized by this Act and the amendments made by this Act) shall be
deposited in the Treasury and used for Federal budget deficit reduction
or, if there is no Federal budget deficit, for reducing the Federal
debt in such manner as the Secretary of the Treasury considers
appropriate.
<all>
Introduced in House
Introduced in House
Referred to the Committee on Ways and Means, and in addition to the Committee on Natural Resources, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Referred to the Committee on Ways and Means, and in addition to the Committee on Natural Resources, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Referred to the Subcommittee on Energy and Mineral Resources.
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