Sec. 216. Amortization of certain mining exploration expenditures
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Section 617 of the Internal Revenue Code of 1986 is amended to read as follows: Any expenditures paid or incurred for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other mineral, and paid or incurred before the beginning of the development stage of the mine, shall be allowed as a deduction ratably over the 84-month period beginning on the date that such expense was paid or incurred. For purposes of subsection (a), any expenditures paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month.
Except as provided in this section, no depreciation or amortization deduction shall be allowed with respect to expenditures described in subsection (a). If any property with respect to which expenditures described in subsection
(a)are paid or incurred is retired or abandoned during the 84-month period described in such subsection, no deduction shall be allowed on account of such retirement or abandonment and the amortization deduction under this section shall continue with respect to such payment. . The item relating to section 617 in the table of sections for part I of subchapter I of chapter 1 of the Internal Revenue Code of 1986 is amended to read as follows: Sec. 617. Amortization of certain mining exploration expenditures. . Section 56(a) of such Code, as amended by section 215(b)(2), is amended by striking paragraph (2). Section 59(e) of such Code, as amended by section 215(b)(3), is amended— in paragraph (2)— in subparagraph (B), by inserting or at the end, in subparagraph (C), by striking the comma at the end and inserting a period, and by striking subparagraph (D), and by striking paragraph
(5)and inserting the following: In the case of any disposition of property to which section 1254 applies (determined without regard to this section), any deduction under paragraph
(1)with respect to amounts which are allocable to such property shall, for purposes of section 1254, be treated as a deduction allowable under section 263(c). . Section 170(e) of such Code is amended— in paragraph (1), by striking 617(d)(1), , and in paragraph (3)(D), by striking 617, . Section 263A(c)(3) of such Code, as amended by section 215(b)(5), is amended by striking 291(b)(2), or 617 and inserting or 291(b)(2) . Section 291(b) of such Code, as amended by section 215(b)(6), is amended— in the heading, by striking , and mineral exploration and development costs by striking paragraph
(1)and inserting the following: In the case of an integrated oil company, the amount allowable as a deduction for any taxable year (determined without regard to this section) under section 263(c) shall be reduced by 30 percent. , in paragraph (2), by striking or 617(a) (as the case may be) , and in paragraph (3), by striking or 617(a) (whichever is appropriate) . Section 312(n), as amended by section 215(b)(7), is amended by striking paragraph
(2)and inserting the following: Any amount allowable as a deduction under section 263(c) in determining taxable income (other than costs incurred in connection with a nonproductive well)— shall be capitalized, and shall be allowed as a deduction ratably over the 60-month period beginning with the month in which such amount was paid or incurred. . Section 703(b) of such Code is amended— in paragraph (1), by adding or at the end, by striking paragraph (2), and by redesignating paragraph
(3)as paragraph (2). Section 751(c) of such Code is amended— by inserting , as in effect on the day before the date of the enactment of the after End Polluter Welfare Act of 2025 section 617(f)(2) , and by striking 617(d)(1), . Section 1254(a)(1)(A)(i) of such Code, as amended by section 215(b)(10), is amended by striking or 617 . Paragraph
(2)of section 1363(c) of such Code is amended to read as follows: In the case of an S corporation, elections under section 901 (relating to taxes of foreign countries and possessions of the United States) shall be made by each shareholder separately. . The amendments made by this section shall apply to expenditures paid or incurred in taxable years beginning after the date of the enactment of this Act.