major integrated oil company

(5) Special rule for major integrated oil companies (A) In general In the case of a major integrated oil company, paragraphs (1) and (4) shall be applied by substituting “7-year” for “24 month”. (B) Major integrated oil company For purposes of this paragraph, the term “major integrated oil company” means, with respect to any taxable year, a producer of crude oil— (i) which has an average daily worldwide production of crude oil of at least 500,000 barrels for the taxable year, (ii) which had gross receipts in excess of $1,000,000,000 for its last taxable year ending during calendar year 2005, and (iii) to which subsection (c) of section 613A does not apply by reason of paragraph (4) of section 613A(d), determined— (I) by substituting “15 percent” for “5 percent” each place it occurs in paragraph (3) of section 613A(d), and (II) without regard to whether subsection (c) of section 613A does not apply by reason of paragraph (2) of section 613A(d). For purposes of clauses (i) and (ii), all persons treated as a single employer under subsections (a) and (b) of section 52 shall be treated as 1 person and, in case of a short taxable year, the rule under section 448(c)(3)(B) shall apply.

Source

26 USC § 167(h)(5)


Scoping language

For purposes of this paragraph
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