foreign oil and gas loss
(i)For purposes of this paragraph, the term “foreign oil and gas loss” means the amount by which— (I)the gross income for the taxable year from sources without the United States and its possessions (whether or not the taxpayer chooses the benefits of this subpart for such taxable year) taken into account in determining the combined foreign oil and gas income for such year, is exceeded by (II)the sum of the deductions properly apportioned or allocated thereto. (ii)For purposes of clause (i), the net operating loss deduction allowable for the taxable year undershall not be taken into account. (iii)For purposes of clause (i), there shall not be taken into account— (I)any foreign expropriation loss (as defined in section 172(h) (as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990)) for the taxable year, or (II)any loss for the taxable year which arises from fire, storm, shipwreck, or other casualty, or from theft, (iv)For purposes of subparagraph (B)(ii)(I), foreign oil extraction losses shall be determined under this paragraph as in effect on the day before the date of the enactment of the Energy Improvement and Extension Act of 2008.