Promoting Domestic Energy Production Act
Summary
What This Bill Does
The Promoting Domestic Energy Production Act amends the corporate alternative minimum tax rules for adjusted financial statement income. It directs taxpayers to reduce adjusted financial statement income by deductions allowed under Internal Revenue Code section 263(c) for intangible drilling and development costs, to the extent those deductions are allowed in taxable income. It also tells taxpayers to disregard depletion expense taken into account on financial statements with respect to those intangible drilling and development costs. The amendments apply to taxable years beginning after December 31, 2025. The practical effect is to let oil and gas companies reflect tax deductions for drilling and development costs when computing the corporate minimum tax base.
Who Benefits and How
Oil and gas producers benefit because intangible drilling and development cost deductions lower adjusted financial statement income for minimum-tax purposes. Domestic energy developers benefit from improved after-tax economics for drilling projects. Energy-sector investors may benefit if projects face less corporate minimum tax friction. Tax accountants and corporate finance teams benefit from clearer statutory treatment of drilling-cost deductions in the minimum-tax calculation.
Who Bears the Burden and How
Treasury and IRS staff must administer the revised adjusted-financial-statement-income rule and issue any needed guidance. Federal taxpayers bear potential revenue loss if affected companies owe less corporate alternative minimum tax. Corporate tax departments must track book depletion expense, tax deductions under section 263(c), and the new post-2025 effective date. Competitors outside oil and gas do not receive the same drilling-cost adjustment.
Key Provisions
- Allows section 263(c) intangible drilling and development cost deductions to reduce adjusted financial statement income.
- Requires taxpayers to disregard financial-statement depletion expense tied to those drilling and development costs.
- Applies the revised corporate minimum-tax treatment to taxable years beginning after December 31, 2025.
- Modifies section 56A(c)(13) rather than changing ordinary income-tax deduction rules.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
Excludes intangible drilling and development cost deductions from adjusted financial statement income for the corporate alternative minimum tax calculation for taxable years after 2025.
Key Policy Areas
Tax, Oil and Gas, Corporate Minimum Tax, Energy
Primary Purpose
Excludes intangible drilling and development cost deductions from adjusted financial statement income for the corporate alternative minimum tax calculation for taxable years after 2025.
Policy Domains
Substantive provisions
Identified Gains
- Oil and gas producers
- Domestic energy developers
- Energy-sector investors
- Corporate tax departments
Identified Costs
- Treasury staff
- IRS administrators
- Federal taxpayers
- Non-energy corporations
Sponsors
Legislative Progress
In CommitteeMr. Carey (for himself, Mr. Vicente Gonzalez of Texas, Mr. …
Referred to the House Committee on Ways and Means.
Introduced in House
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "IRS"
- → Internal Revenue Service
- "Treasury"
- → Department of the Treasury
Key Definitions
Terms defined in this bill
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology