S. 510

Financing Our Energy Future Act This bill allows a publicly traded partnership to derive income from certain clean energy-related activities and still be treated as a partnership for federal income tax purposes. As background, a publicly traded partnership is a partnership whose interests are traded on an established securities market (or readily tradable on a secondary market). A publicly traded partnership generally is treated as a corporation for federal income tax purposes unless 90% or more of such partnership’s gross income is qualifying income. Under current law, qualifying income includes • interest and dividends; • real property rents; • gain from the sale (or disposition) of real property; • income from certain activities related to minerals and natural resources, source carbon dioxide, and the transportation or storage of certain fuels; and • gain from the sale (or disposition) of a capital asset or commodities. Under the bill, the qualifying income is expanded to include income derived from • electric power (or thermal energy) generated from renewable energy sources (e.g., wind and solar energy), qualified gasification projects, or advanced nuclear facilities; • accepting or processing open-loop biomass or municipal solid waste (by certain facilities); • the storage of electric power or thermal energy using certain energy storage technology; • the generation, storage, or distribution of electric power (or thermal energy) using combined heat and power system property; • fuels that use certain carbon oxides as primary feedstock; • certain renewable chemicals; • transportation or storage of liquefied or compressed hydrogen; • the conversion of renewable biomass; and • certain carbon capture and sequestration facilities.