S.Amdt. 1803

SA 1803. Ms. KLOBUCHAR submitted an amendment intended to be proposed
to amendment SA 1618 proposed by Mr. McConnell (for Mr. Hatch (for
himself and Ms. Murkowski)) to the bill H.R. 1, to provide for
reconciliation pursuant to titles II and V of the concurrent resolution
on the budget for fiscal year 2018; which was ordered to lie on the
table; as follows:

At the end of part III of subtitle A of title I, insert the
following:

SEC. 11030. DECREASE IN REQUIRED DISTANCE AWAY FROM HOME FOR
ABOVE-THE-LINE DEDUCTION FOR TRAVEL EXPENSES OF
MEMBERS OF A RESERVE COMPONENT OF THE ARMED
FORCES.

(a) In General.--Section 62(a)(2)(E) is amended by striking
``100 miles'' and inserting ``50 miles''.
(b) Effective Date.--The amendment made by subsection (a)
shall apply to taxable years beginning after December 31,
2016.
(c) Offset.--
(1) Inclusion of foreign base company oil related income.--
Subsection (a) of section 954, as amended by section 14211,
is amended--
(A) by striking ``and'' at the end of paragraph (2),
(B) by striking the period at the end of paragraph (3) and
inserting ``, and'', and
(C) by adding at the end the following new paragraph:
``(4) the foreign base company oil related income for the
taxable year (determined under subsection (g) and reduced as
provided in subsection (b)(5)).''.
(2) Conforming amendments.--
(A) Section 952(c)(1)(B)(iii), as amended by section 14211,
is amended--
(i) by redesignating subclauses (I) through (IV) as
subclauses (II) through (V), respectively, and
(ii) by inserting before subclause (II), as so
redesignated, the following new subclause:

``(I) foreign base company oil related income,''.

(B) Section 954(b), as amended by section 14211, is
amended--
(i) by adding at the end of paragraph (4) the following:
``The preceding sentence shall not apply to foreign base
company oil-related income described in subsection (a)(4).'',
(ii) by striking ``and the foreign base company services
income'' in paragraph (5) and inserting ``the foreign base
company services income, and the foreign base company oil
related income'', and
(iii) by adding at the end the following new paragraph:
``(6) Foreign base company oil related income not treated
as another kind of base company income.--Income of a
corporation which is foreign base company oil related income
shall not be considered foreign base company income of such
corporation under paragraph (2) or (3) of subsection (a).''.
(C) Section 954, as amended by section 14211, is amended by
inserting before subsection (h) the following:
``(g) Foreign Base Company Oil Related Income.--For
purposes of this section--
``(1) In general.--Except as otherwise provided in this
subsection, the term `foreign base company oil related
income' means foreign oil related income (within the meaning
of paragraphs (2) and (3) of section 907(c)) other than
income derived from a source within a foreign country in
connection with--
``(A) oil or gas which was extracted from an oil or gas
well located in such foreign country, or
``(B) oil, gas, or a primary product of oil or gas which is
sold by the foreign corporation or a related person for use
or consumption within such country or is loaded in such
country on a vessel or aircraft as fuel for such vessel or
aircraft.
Such term shall not include any foreign personal holding
company income (as defined in subsection (c)).
``(2) Paragraph (1) applies only where corporation has
produced 1,000 barrels per day or more.--
``(A) In general.--The term `foreign base company oil
related income' shall not include any income of a foreign
corporation if

[[Page S7647]]

such corporation is not a large oil producer for the taxable
year.
``(B) Large oil producer.--For purposes of subparagraph
(A), the term `large oil producer' means any corporation if,
for the taxable year or for the preceding taxable year, the
average daily production of foreign crude oil and natural gas
of the related group which includes such corporation equaled
or exceeded 1,000 barrels.
``(C) Related group.--The term `related group' means a
group consisting of the foreign corporation and any other
person who is a related person with respect to such
corporation.
``(D) Average daily production of foreign crude oil and
natural gas.--For purposes of this paragraph, the average
daily production of foreign crude oil or natural gas of any
related group for any taxable year (and the conversion of
cubic feet of natural gas into barrels) shall be determined
under rules similar to the rules of section 613A except that
only crude oil or natural gas from a well located outside the
United States shall be taken into account.''.
(3) Effective date.--The amendments made by this subsection
shall apply to taxable years of foreign corporations
beginning after December 31, 2017, and to taxable years of
United States shareholders with or within which such taxable
years of foreign corporations end.
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