[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2652 Introduced in House (IH)]
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119th CONGRESS
1st Session
H. R. 2652
To amend the Internal Revenue Code of 1986 to provide incentives for
relocating manufacturing to the United States, permanent full expensing
for qualified property, and for other purposes.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
April 3, 2025
Mr. Roy (for himself and Mr. Moore of Alabama) introduced the following
bill; which was referred to the Committee on Ways and Means
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to provide incentives for
relocating manufacturing to the United States, permanent full expensing
for qualified property, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Bring Entrepreneurial Advancements
To Consumers Here In North America Act''.
SEC. 2. TAX INCENTIVES FOR RELOCATING MANUFACTURING TO THE UNITED
STATES.
(a) Accelerated Depreciation for Nonresidential Real Property.--
Section 168 of the Internal Revenue Code of 1986 is amended by adding
at the end the following new subsection:
``(n) Accelerated Depreciation for Nonresidential Real Property
Acquired in Connection With the Relocation of Manufacturing to the
United States.--
``(1) Treatment as 20-year property.--For purposes of this
section, qualified nonresidential real property shall be
treated as 20-year property.
``(2) Application of bonus depreciation.--For application
of bonus depreciation to qualified nonresidential real
property, see subsection (k).
``(3) Qualified nonresidential real property.--For purposes
of this subsection, the term `qualified nonresidential real
property' means nonresidential real property placed in service
in the United States by a qualified manufacturer if such
property is acquired by such qualified manufacturer in
connection with a qualified relocation of manufacturing.
``(4) Qualified manufacturer.--For purposes of this
subsection, the term `qualified manufacturer' means any person
engaged in the trade or business of manufacturing any tangible
personal property.
``(5) Qualified relocation of manufacturing.--For purposes
of this subsection--
``(A) In general.--The term `qualified relocation
of manufacturing' means, with respect to any qualified
manufacturer, the relocation of the manufacturing of
any tangible personal property from a foreign country
to the United States.
``(B) Relocation of property not required.--For
purposes of subparagraph (A), manufacturing shall not
fail to be treated as relocated merely because property
used in such manufacturing was not relocated.
``(C) Relocation of not less than equivalent
productive capacity required.--For purposes of
subparagraph (A), manufacturing shall not be treated as
relocated unless the property manufactured in the
United States is substantially identical to the
property previously manufactured in a foreign country
and the increase in the units of production of such
property in the United States by the qualified
manufacturer is not less than the reduction in the
units of production of such property in such foreign
country by such qualified manufacturer.
``(6) Application to possessions of the united states.--For
purposes of this subsection, the term `United States' includes
any possession of the United States.''.
(b) Exclusion of Gain on Disposition of Property in Connection With
Qualified Relocation of Manufacturing.--
(1) In general.--Part III of subchapter B of chapter 1 of
such Code is amended by inserting after section 139I the
following new section:
``SEC. 139J. EXCLUSION OF GAIN ON DISPOSITION OF PROPERTY IN CONNECTION
WITH QUALIFIED RELOCATION OF MANUFACTURING.
``(a) In General.--In the case of a qualified manufacturer, gross
income shall not include gain from the sale or exchange of qualified
relocation disposition property.
``(b) Qualified Relocation Disposition Property.--For purposes of
this section, the term `qualified relocation disposition property'
means any property which--
``(1) is sold or exchanged by a qualified manufacturer in
connection with a qualified relocation of manufacturing, and
``(2) was used by such qualified manufacturer in the trade
or business of manufacturing any tangible personal property in
the foreign country from which such manufacturing is being
relocated.
``(c) Other Terms.--Terms used in this section which are also used
in subsection (n) of section 168 shall have the same meaning when used
in this section as when used in such subsection.''.
(2) Clerical amendment.--The table of sections for part III
of subchapter B of chapter 1 of such Code is amended by
inserting after the item relating to section 139I the following
new item:
``Sec. 139J. Exclusion of gain on disposition of property in connection
with qualified relocation of
manufacturing.''.
(c) Effective Dates.--
(1) Accelerated depreciation.--The amendment made by
subsection (a) shall apply to property placed in service after
the date of the enactment of this Act.
(2) Exclusion of gain.--The amendments made by subsection
(b) shall apply to sales and exchanges after the date of the
enactment of this Act.
SEC. 3. PERMANENT FULL EXPENSING FOR QUALIFIED PROPERTY.
(a) In General.--Paragraph (6) of section 168(k) of the Internal
Revenue Code of 1986 is amended to read as follows:
``(6) Applicable percentage.--For purposes of this
subsection, the term `applicable percentage' means, in the case
of property placed in service (or, in the case of a specified
plant described in paragraph (5), a plant which is planted or
grafted) after September 27, 2017, 100 percent.''.
(b) Conforming Amendments.--
(1) Section 168(k) of the Internal Revenue Code of 1986 is
amended--
(A) in paragraph (2)--
(i) in subparagraph (A)--
(I) in clause (i)(V), by inserting
``and'' at the end;
(II) in clause (ii), by striking
``clause (ii) of subparagraph (E),
and'' and inserting ``clause (i) of
subparagraph (E).''; and
(III) by striking clause (iii);
(ii) in subparagraph (B)--
(I) in clause (i)--
(aa) by striking subclauses
(II) and (III); and
(bb) by redesignating
subclauses (IV) through (VI) as
subclauses (II) through (IV),
respectively;
(II) by striking clause (ii); and
(III) by redesignating clauses
(iii) and (iv) as clauses (ii) and
(iii), respectively;
(iii) in subparagraph (C)--
(I) in clause (i), by striking
``and subclauses (II) and (III) of
subparagraph (B)(i)''; and
(II) in clause (ii), by striking
``subparagraph (B)(iii)'' and inserting
``subparagraph (B)(ii)''; and
(iv) in subparagraph (E)--
(I) by striking clause (i); and
(II) by redesignating clauses (ii)
and (iii) as clauses (i) and (ii),
respectively; and
(B) in paragraph (5)(A), by striking ``planted
before January 1, 2027, or is grafted before such date
to a plant that has already been planted,'' and
inserting ``planted or grafted''.
(2) Section 460(c)(6)(B) of such Code is amended by
striking ``which'' and all that follows through the period and
inserting ``which has a recovery period of 7 years or less.''.
(c) Effective Date.--The amendments made by this section shall take
effect as if included in section 13201 of Public Law 115-97.
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