1. Treatment of foreign oil related income as subpart F income (a) In general Section 954(a) of the Internal Revenue Code of 1986 is amended by striking and at the end of paragraph (2), by striking the period at the end of paragraph (3) and inserting , and , and by adding at the end the following new paragraph: (4) the foreign base company oil related income for the taxable year (determined under subsection (g) and reduced as provided in subsection (b)(5)). . (b) Foreign base company oil related income Section 954 of the Internal Revenue Code of 1986 is amended by inserting after subsection (e) the following new subsection: (g) Foreign base company oil related income For purposes of this section— (1) In general Except as otherwise provided in this subsection, the term foreign base company oil related income means foreign oil related income (within the meaning of paragraphs (2) and (3) of section 907(c)) other than income derived from a source within a foreign country in connection with— (A) oil or gas which was extracted from an oil or gas well located in such foreign country, or (B) oil, gas, or a primary product of oil or gas which is sold by the foreign corporation or a related person for use or consumption within such country or is loaded in such country on a vessel or aircraft as fuel for such vessel or aircraft. Such term shall not include any foreign personal holding company income (as defined in subsection (c)). (2) Paragraph (1) applies only where corporation has produced 1,000 barrels per day or more (A) In general The term foreign base company oil related income shall not include any income of a foreign corporation if such corporation is not a large oil producer for the taxable year. (B) Large oil producer For purposes of subparagraph (A), the term large oil producer means any corporation if, for the taxable year or for the preceding taxable year, the average daily production of foreign crude oil and natural gas of the related group which includes such corporation equaled or exceeded 1,000 barrels.