S. 510 — Financing Our Energy Future Act

This section expands qualifying income under IRC §7704(d)(1)(E)—allowing publicly traded partnerships (PTPs) to be taxed as partnerships rather than corporations if 90% or more of gross income is qualifying income—to encompass income and gains from an array of green energy activities (e.g., (ii) generation of electric power or thermal energy using qualified energy resources; (iii) operation of energy property; (v) storage of electric power or thermal energy using energy storage technology; (vi) generation, storage, or distribution using combined heat and power system property; (vii) transportation or storage of specified fuels or hydrogen; (x) electric power from qualifying gasification projects; (xi) electric power generation, storage, or carbon capture at qualified carbon oxide facilities; (xii) electric power from advanced nuclear facilities; (xiii) production, storage, or transportation of specified renewable chemicals), for taxable years beginning after December 31, 2025.