H.R. 2545

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2545 Introduced in House (IH)]

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119th CONGRESS
1st Session
H. R. 2545

To amend the Internal Revenue Code of 1986 to extend the publicly 
traded partnership ownership structure to energy power generation 
projects and transportation fuels, and for other purposes.

_______________________________________________________________________

IN THE HOUSE OF REPRESENTATIVES

April 1, 2025

Mr. Estes (for himself and Mr. Thompson of California) introduced the 
following bill; which was referred to the Committee on Ways and Means

_______________________________________________________________________

A BILL

To amend the Internal Revenue Code of 1986 to extend the publicly 
traded partnership ownership structure to energy power generation 
projects and transportation fuels, and for other purposes.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the ``Financing Our Energy Future Act''.

SEC. 2. GREEN ENERGY PUBLICLY TRADED PARTNERSHIPS.

(a) In General.--Section 7704(d)(1)(E) of the Internal Revenue Code 
of 1986 is amended--
(1) by striking ``income and gains derived from the 
exploration'' and inserting ``income and gains derived from--
``(i) the exploration'',
(2) by inserting ``or'' before ``industrial source'', and
(3) by striking ``, or the transportation or storage'' and 
all that follows and inserting the following:
``(ii) the generation of electric power or 
thermal energy exclusively using any qualified 
energy resource (as defined in section 
45(c)(1)),
``(iii) the operation of energy property 
(as defined in section 48(a)(3), determined 
without regard to any date by which the 
construction of the facility is required to 
begin),
``(iv) in the case of a facility described 
in paragraph (3) or (7) of section 45(d) 
(determined without regard to any placed in 
service date or date by which construction of 
the facility is required to begin), the 
accepting or processing of open-loop biomass or 
municipal solid waste,
``(v) the storage of electric power or 
thermal energy exclusively using energy storage 
technology (as defined in section 48(c)(6)),
``(vi) the generation, storage, or 
distribution of electric power or thermal 
energy exclusively using energy property that 
is combined heat and power system property (as 
defined in section 48(c)(3), determined without 
regard to subparagraph (B)(iii) thereof and 
without regard to any date by which the 
construction of the facility is required to 
begin),
``(vii) the transportation or storage of--
``(I) any fuel described in 
subsection (b), (c), (d), (e), or (k) 
of section 6426, or
``(II) liquified hydrogen or 
compressed hydrogen,
``(viii) the conversion of renewable 
biomass (as defined in subparagraph (I) of 
section 211(o)(1) of the Clean Air Act (as in 
effect on the date of the enactment of this 
clause)) into renewable fuel (as defined in 
subparagraph (J) of such section as so in 
effect), or the storage or transportation of 
such fuel,
``(ix) the production, storage, or 
transportation of any fuel which--
``(I) uses as its primary feedstock 
carbon oxides captured from an 
anthropogenic source or the atmosphere,
``(II) does not use as its primary 
feedstock carbon oxide which is 
deliberately released from naturally 
occurring subsurface springs, and
``(III) is determined by the 
Secretary, after consultation with the 
Secretary of Energy and the 
Administrator of the Environmental 
Protection Agency, to achieve a 
reduction of not less than a 60 percent 
in lifecycle greenhouse gas emissions 
(as defined in section 211(o)(1)(H) of 
the Clean Air Act, as in effect on the 
date of the enactment of this clause) 
compared to baseline lifecycle 
greenhouse gas emissions (as defined in 
section 211(o)(1)(C) of such Act, as so 
in effect),
``(x) the generation of electric power from 
a qualifying gasification project (as defined 
in section 48B(c)(1) without regard to 
subparagraph (C)) that is described in section 
48B(d)(1)(B),
``(xi) in the case of a qualified facility 
(as defined in section 45Q(d), without regard 
to any date by which construction of the 
facility is required to begin) not less than 50 
percent of the total carbon oxide production of 
which is qualified carbon oxide (as defined in 
section 45Q(c))--
``(I) the generation, availability 
for such generation, or storage of 
electric power at such facility, or
``(II) the capture of carbon 
dioxide by such facility,
``(xii) the generation of electric power or 
energy from any advanced nuclear facility (as 
defined in section 45J(d)(2)), or
``(xiii) the production, storage, or 
transportation of any renewable chemical 
which--
``(I) is produced in the United 
States (or in a territory or possession 
of the United States) from renewable 
biomass,
``(II) is not less than 95 percent 
biobased content,
``(III) is not sold or used for the 
production of any food, feed, fuel, or 
pharmaceuticals,
``(IV) is approved to use the USDA 
Certified Biobased Product label under 
section 9002(b) of the Farm Security 
and Rural Investment Act of 2002 (7 
U.S.C. 8102(b)), and
``(V) is a chemical intermediate 
(as such term is defined in section 
3201.109 of title 7, Code of Federal 
Regulations (or successor 
regulations)),''.
(b) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2025.
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