To amend the Internal Revenue Code of 1986 to provide that interest on indebtedness used to finance the furnishing or sale of rate-regulated electric energy or natural gas in the United States shall be allocated solely to sources within the United States.

Amends Internal Revenue Code provisions relating to rules for allocating interest to provide, in general, that interest on any qualified infrastructure indebtedness shall be allocated and apportioned solely to sources within the United States, and such indebtedness shall not be taken into account in allocating and apportioning other interest expense. Defines the term "qualified infrastructure indebtedness" to mean any indebtedness incurred to carry on the trade or business of the furnishing or sale of electric energy or natural gas in the United States, or to acquire, construct, or otherwise finance property used predominantly in such trade or business.