This bill modifies the tax treatment of U.S. corporations with foreign oil and gas operations. It requires foreign oil and gas extraction income to be included in calculations that determine how much tax American companies owe on worldwide income earned through foreign subsidiaries. The legislation also expands the definition of taxable foreign oil and gas income to include extraction from oil shale and tar sands, closing what supporters view as a tax loophole. Additionally, it restricts foreign tax credits for "dual capacity taxpayers"—companies that receive special economic benefits from foreign governments while also paying taxes there—by limiting their ability to claim credits for payments that exceed what a standard taxpayer would owe. The changes take effect for tax years beginning after the bill's enactment, with the dual capacity taxpayer rules applying to tax years after December 31, 2026.