Amortization of certain mining exploration expenditures

(a) In general Section 617 of the Internal Revenue Code of 1986 is amended to read as follows: 617. Amortization of certain mining exploration expenditures (a) In general Any expenditures paid or incurred for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other mineral, and paid or incurred before the beginning of the development stage of the mine, shall be allowed as a deduction ratably over the 84-month period beginning on the date that such expense was paid or incurred. (b) Mid-Month convention For purposes of subsection (a), any expenditures paid or incurred during any month shall be treated as paid or incurred on the mid-point of such month. (c) Exclusive method Except as provided in this section, no depreciation or amortization deduction shall be allowed with respect to expenditures described in subsection (a). (d) Treatment upon abandonment If any property with respect to which expenditures described in subsection (a) are paid or incurred is retired or abandoned during the 84-month period described in such subsection, no deduction shall be allowed on account of such retirement or abandonment and the amortization deduction under this section shall continue with respect to such payment.. (b) Conforming amendments (1) The item relating to section 617 in the table of sections for part I of subchapter I of chapter 1 of the Internal Revenue Code of 1986 is amended to read as follows: Sec. 617. Amortization of certain mining exploration expenditures.. (2) Section 56(a) of such Code, as amended by section 215(b)(2), is amended by striking paragraph (2). (3) Section 59(e) of such Code, as amended by section 215(b)(3), is amended— (A) in paragraph (2)— (i) in subparagraph (B), by inserting or at the end, (ii) in subparagraph (C), by striking the comma at the end and inserting a period, and (iii) by striking subparagraph (D), and (B) by striking paragraph (5) and inserting the following: (5) Dispositions In the case of any disposition of property to which section 1254 applies (determined without regard to this section), any deduction under paragraph (1) with respect to amounts which are allocable to such property shall, for purposes of section 1254, be treated as a deduction allowable under section 263(c).. (4) Section 170(e) of such Code is amended— (A) in paragraph (1), by striking 617(d)(1),, and (B) in paragraph (3)(D), by striking 617,. (5) Section 263A(c)(3) of such Code, as amended by section 215(b)(5), is amended by striking 291(b)(2), or 617 and inserting or 291(b)(2). (6) Section 291(b) of such Code, as amended by section 215(b)(6), is amended— (A) in the heading, by striking and mineral exploration and development costs, (B) by striking paragraph (1) and inserting the following: (1) In general In the case of an integrated oil company, the amount allowable as a deduction for any taxable year (determined without regard to this section) under section 263(c) shall be reduced by 30 percent., (C) in paragraph (2), by striking or 617(a) (as the case may be), and (D) in paragraph (3), by striking or 617(a) (whichever is appropriate). (7) Section 312(n), as amended by section 215(b)(7), is amended by striking paragraph (2) and inserting the following: (2) Intangible drilling costs Any amount allowable as a deduction under section 263(c) in determining taxable income (other than costs incurred in connection with a nonproductive well)— (A) shall be capitalized, and (B) shall be allowed as a deduction ratably over the 60-month period beginning with the month in which such amount was paid or incurred.. (8) Section 703(b) of such Code is amended— (A) in paragraph (1), by adding or at the end, (B) by striking paragraph (2), and (C) by redesignating paragraph (3) as paragraph (2). (9) Section 751(c) of such Code is amended— (A) by inserting, as in effect on the day before the date of the enactment of the End Polluter Welfare Act of 2025 after section 617(f)(2), and (B) by striking 617(d)(1),. (10) Section 1254(a)(1)(A)(i) of such Code, as amended by section 215(b)(10), is amended by striking or 617. (11) Paragraph (2) of section 1363(c) of such Code is amended to read as follows: (2) Exception In the case of an S corporation, elections under section 901 (relating to taxes of foreign countries and possessions of the United States) shall be made by each shareholder separately.. (c) Effective date The amendments made by this section shall apply to expenditures paid or incurred in taxable years beginning after the date of the enactment of this Act.