Integrated oil companies would pay a fee on profits above a benchmark

Integrated oil companies would owe a fee equal to 50% of their excess profit. An applicable taxpayer is an integrated oil company. Excess profit is adjusted taxable income above a benchmark based on the company's average adjusted taxable income for the five taxable years beginning after December 31, 2020, leaving out its highest year and adding 10%. The fee is in addition to other taxes. For a foreign company, adjusted income includes only income effectively connected with business in the United States. Companies in the specified groups under common control are treated as one person. The fee applies to taxable years beginning after December 31, 2025.

The bill directs portions of the fee revenue to specified federal trust funds. The bill directs 0.5435% of the fee to the Highway Trust Fund and the same share to the Leaking Underground Storage Tank Trust Fund. The Mass Transit Account transfer is 15.63% of fee amounts appropriated to the Highway Trust Fund after the specified Highway Trust Fund transfer is applied. The transfers apply to fee amounts received or appropriated as specified in the bill.

The bill would allow taxpayers to deduct the fee under the federal income tax rules listed. The deduction is for the fee imposed under section 5896.