President Barack Obama on September 12, 2011 sent to Congress legislative language and analysis for the $447 billion American Jobs Act that he proposed the week earlier, asking Congress to adopt the $467 billion in revenue raisers that would more than offset the cost of the package. The key proposed revenue offset is related to limitations for high income individuals in the computation of their taxable income. In addition, there are proposals to tax the carried interest in certain investment partnerships as ordinary income and the repeal of several oil and gas provisions. In the international tax area, two revenue raisers were noted: the modifi cation of foreign tax credit rules for dual capacity taxpayers and the creation of a new foreign tax credit basket for oil and gas income.