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. (C) Related group The term related group means a group consisting of the foreign corporation and any other person who is a related person with respect to such corporation. (D) Average daily production of foreign crude oil and natural gas For purposes of this paragraph, the average daily production of foreign crude oil or natural gas of any related group for any taxable year (and the conversion of cubic feet of natural gas into barrels) shall be determined under rules similar to the rules of section 613A except that only crude oil or natural gas from a well located outside the United States shall be taken into account. . (c) Conforming amendments (1) Section 952(c)(1)(B)(iii) of the Internal Revenue Code of 1986 is amended by redesignating subclauses (I) through (IV) as subclause (II) through (V), respectively, and by inserting before subclause (II) (as so redesignated) the following: (I) foreign base company oil related income, . (2) Section 954(b) of such Code is amended— (A) by inserting at the end of paragraph (4) the following: The preceding sentence shall not apply to foreign base company oil-related income described in subsection (a)(4). , (B) by striking and the foreign base company services income in paragraph (5) and inserting the foreign base company services income, and the foreign base company oil related income , and (C) by adding at the end the following new paragraph: (6) Foreign base company oil related income not treated as another kind of base company income Income of a corporation which is foreign base company oil related income shall not be considered foreign base company income of such corporation under paragraph (2) or (3) of subsection (a). . (d) Effective date The amendments made by this section shall apply to taxable years of foreign