a specific economic benefit (as determined in accordance with regulations) from such country or possession. (3) Generally applicable income tax For purposes of this subsection— (A) In general The term generally applicable income tax means an income tax (or a series of income taxes) which is generally imposed under the laws of a foreign country or possession on income derived from the conduct of a trade or business within such country or possession. (B) Exceptions Such term shall not include a tax unless it has substantial application, by its terms and in practice, to— (i) persons who are not dual capacity taxpayers, and (ii) persons who are— (I) citizens or residents of the foreign country or possession, or (II) organized or incorporated under the laws of the foreign country or possession. (4) Fossil fuel For purposes of this subsection, the term fossil fuel means coal, petroleum, natural gas, or any derivative of coal, petroleum, or natural gas that is used for fuel. . (b) Effective date The amendments made by this section shall apply to taxes paid or accrued in taxable years beginning after the date of the enactment of this Act. (c) Special rule for treaties Notwithstanding section 894 or 7852(d) of the Internal Revenue Code of 1986, the amendments made by this section shall apply without regard to any treaty obligation of the United States. 122. Increase in oil spill liability trust fund financing rate (a) In general Section 4611 of the Internal Revenue Code of 1986 is amended— (1) in subsection (c)(2)(B)— (A) in clause (i), by striking and at the end, (B) in clause (ii), by striking the period at the end and inserting , and , and (C) by adding at the end the following: (iii) in the case of crude oil received or petroleum products entered after December 31, 2020, 10 cents a barrel. , and (2) by striking subsection (f) and inserting the following: (f) Application of Oil Spill Liability Trust Fund financing rate The Oil Spill Liability Trust Fund financing rate under subsection (c) shall apply on and after