A bill to amend the Internal Revenue Code of 1986 to include foreign oil and gas extraction income in net CFC tested income, to include income from the extraction of minerals from oil shale and tar sands in the definitions of foreign oil and gas extraction income and foreign oil related income, and for other purposes.

S. 5350, introduced by Sen. Martin Heinrich (D-NM) on August 6, 2026, would amend the Internal Revenue Code of 1986 as it applies to U.S. multinational companies' foreign oil and gas operations. Based on the title, it would (1) include foreign oil and gas extraction income in the calculation of "net CFC tested income" — a category used in U.S. international tax rules for controlled foreign corporations — and (2) expand the definitions of "foreign oil and gas extraction income" and "foreign oil related income" to specifically include income from extracting minerals from oil shale and tar sands.

The bill would primarily affect U.S. corporations with foreign subsidiaries engaged in oil and gas extraction, including from oil shale and tar sands deposits, by changing how that income is treated under federal tax law. The practical financial or tax-rate effects on these companies are not stated in the available material.

The bill was introduced in the Senate on August 6, 2026, and referred to committee, as is standard for newly introduced legislation. Its full text has not yet been published, so no further detail on specific mechanisms, effective dates, or revenue effects is available. Next steps would typically include committee consideration before any vote by the full Senate; there is no indication yet of a hearing, markup, or scheduled floor action.

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