Sec. 8101. Conforming amendments related to multiple sections
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Section 38(b), as amended by the preceding provisions of this Act, is amended— by redesignating paragraphs (4), (5), (7), (8), (13), (20), and
(33)as paragraphs (3), (4), (5), (6), (7), (8), and (9), respectively, by adding plus at the end of paragraph
(8)(as so redesignated), and by striking the comma at the end of paragraph
(9)(as so redesignated) and inserting a period. Section 1016(a), as amended by the preceding provisions of this Act, is amended— by striking the last two sentences of paragraph (2), in paragraph
(4)by striking (not including and all that follows through 1921) , by striking paragraph (12), by redesignating paragraphs (11), (14), (16), (17), (18), (21), (23), (26), (38), and
(39)as paragraphs (9), (10), (11), (12), (13), (14), (15), (16), (17), and (18), respectively, and by adding and at the end of paragraph
(17)(as so redesignated). Section 1223, as amended by the preceding provisions of this Act, is amended by redesignating paragraphs (9), (10), (11), (12), and
(15)as paragraphs (6), (7), (8),
(9)and (10), respectively. Subchapter B of chapter 1, as amended by this Act, is amended by striking part XI (and by striking the item relating to such part from the table of parts for such subchapter). Section 263(c) is amended— by striking all that precedes and except as provided in subsection
(i)and inserting the following: Notwithstanding subsection (a), , and by adding at the end the following new paragraph: In the case of a corporation which is an integrated oil company, the amount allowable as a deduction for any taxable year (determined without regard to this paragraph) under paragraph
(1)shall be reduced by 30 percent. The amount not allowable as a deduction under paragraph
(1)for any taxable year by reason of subparagraph
(A)shall be allowable as a deduction ratably over the 60-month period beginning with the month in which the costs are paid or incurred. For purposes of section 1254, any deduction under subparagraph
(B)shall be treated as a deduction allowable under paragraph (1). For purposes of this paragraph, the term integrated oil company means, with respect to any taxable year, any producer of crude oil to whom subsection
(c)of section 613A does not apply by reason of paragraph
(2)or
(4)of section 613A(d) (as such provisions were in effect before their repeal by the Tax Reform Act of 2014 ). The portion of the adjusted basis of any property which is attributable to amounts to which subparagraph
(A)applied shall not be taken into account for purposes of determining depletion under section 611. . Section 163 is amended by redesignating subsection
(n)as subsection
(o)and by inserting after subsection
(m)the following new subsection: For purposes of this subtitle, in the case of a corporation, the amount allowable as a deduction under this chapter (determined without regard to this subsection) with respect to the amount described in paragraph
(2)shall be reduced by 20 percent. In the case of a financial institution which is a bank (as defined in section 585(a)(2)), the amount described in this paragraph is the amount of interest on indebtedness incurred or continued to purchase or carry obligations acquired after December 31, 1982, and before August 8, 1986, the interest on which is exempt from taxes for the taxable year, to the extent that a deduction would (but for this paragraph or section 265(b)) be allowable with respect to such interest for such taxable year. Unless the taxpayer (under regulations prescribed by the Secretary) establishes otherwise, the amount determined under subparagraph
(A)shall be an amount which bears the same ratio to the aggregate amount allowable (determined without regard to this section and section 265(b)) to the taxpayer as a deduction for interest for the taxable year as— the taxpayer’s average adjusted basis (within the meaning of section 1016) of obligations described in subparagraph (A), bears to such average adjusted basis for all assets of the taxpayer. For purposes of this paragraph, the term interest includes amounts (whether or not designated as interest) paid in respect of deposits, investment certificates, or withdrawable or repurchasable shares. For application of this subparagraph to certain obligations issued after August 7, 1986, see section 265(b)(3) (as in effect before the enactment of the Tax Reform Act of 2014 ). That portion of any obligation not taken into account under paragraph (2)(A) of section 265(b) (as so in effect) by reason of paragraph
(7)of such section shall be treated for purposes of this section as having been acquired on August 7, 1986. . Section 1277(c) is amended by striking section 291(e)(1)(B)(ii) and inserting section 163(n)(2)(B) . Section 1363(b)(3), as amended by the preceding provisions of this Act, is amended by striking section 291 and inserting section 163(n) . Except as otherwise provided in this Act with respect to amendments made to section 291 of the Internal Revenue Code of 1986, the amendments made this subsection shall apply to taxable years beginning after December 31, 2014.