I
119THCONGRESS
1
STSESSION 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
APRIL3, 2025
Mr. R
OY(for himself and Mr. MOOREof 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 Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Bring Entrepreneurial 4
Advancements To Consumers Here In North America 5
Act’’. 6
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SEC. 2. TAX INCENTIVES FOR RELOCATING MANUFAC-1
TURING TO THE UNITED STATES. 2
(a) A
CCELERATED DEPRECIATION FOR NONRESI-3
DENTIALREALPROPERTY.—Section 168 of the Internal 4
Revenue Code of 1986 is amended by adding at the end 5
the following new subsection: 6
‘‘(n) A
CCELERATEDDEPRECIATION FOR NONRESI-7
DENTIALREALPROPERTYACQUIRED INCONNECTION 8
W
ITH THERELOCATION OF MANUFACTURING TO THE 9
U
NITEDSTATES.— 10
‘‘(1) T
REATMENT AS 20-YEAR PROPERTY.—For 11
purposes of this section, qualified nonresidential real 12
property shall be treated as 20-year property. 13
‘‘(2) A
PPLICATION OF BONUS DEPRECIATION .— 14
For application of bonus depreciation to qualified 15
nonresidential real property, see subsection (k). 16
‘‘(3) Q
UALIFIED NONRESIDENTIAL REAL PROP -17
ERTY.—For purposes of this subsection, the term 18
‘qualified nonresidential real property’ means non-19
residential real property placed in service in the 20
United States by a qualified manufacturer if such 21
property is acquired by such qualified manufacturer 22
in connection with a qualified relocation of manufac-23
turing. 24
‘‘(4) Q
UALIFIED MANUFACTURER .—For pur-25
poses of this subsection, the term ‘qualified manu-26
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facturer’ means any person engaged in the trade or 1
business of manufacturing any tangible personal 2
property. 3
‘‘(5) Q
UALIFIED RELOCATION OF MANUFAC -4
TURING.—For purposes of this subsection— 5
‘‘(A) I
N GENERAL.—The term ‘qualified 6
relocation of manufacturing’ means, with re-7
spect to any qualified manufacturer, the reloca-8
tion of the manufacturing of any tangible per-9
sonal property from a foreign country to the 10
United States. 11
‘‘(B) R
ELOCATION OF PROPERTY NOT RE -12
QUIRED.—For purposes of subparagraph (A), 13
manufacturing shall not fail to be treated as re-14
located merely because property used in such 15
manufacturing was not relocated. 16
‘‘(C) R
ELOCATION OF NOT LESS THAN 17
EQUIVALENT PRODUCTIVE CAPACITY RE -18
QUIRED.—For purposes of subparagraph (A), 19
manufacturing shall not be treated as relocated 20
unless the property manufactured in the United 21
States is substantially identical to the property 22
previously manufactured in a foreign country 23
and the increase in the units of production of 24
such property in the United States by the quali-25
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fied manufacturer is not less than the reduction 1
in the units of production of such property in 2
such foreign country by such qualified manufac-3
turer. 4
‘‘(6) A
PPLICATION TO POSSESSIONS OF THE 5
UNITED STATES.—For purposes of this subsection, 6
the term ‘United States’ includes any possession of 7
the United States.’’. 8
(b) E
XCLUSION OFGAIN ONDISPOSITION OFPROP-9
ERTY INCONNECTIONWITHQUALIFIEDRELOCATION OF 10
M
ANUFACTURING.— 11
(1) I
N GENERAL.—Part III of subchapter B of 12
chapter 1 of such Code is amended by inserting 13
after section 139I the following new section: 14
‘‘SEC. 139J. EXCLUSION OF GAIN ON DISPOSITION OF PROP-15
ERTY IN CONNECTION WITH QUALIFIED RE-16
LOCATION OF MANUFACTURING. 17
‘‘(a) I
NGENERAL.—In the case of a qualified manu-18
facturer, gross income shall not include gain from the sale 19
or exchange of qualified relocation disposition property. 20
‘‘(b) Q
UALIFIEDRELOCATIONDISPOSITIONPROP-21
ERTY.—For purposes of this section, the term ‘qualified 22
relocation disposition property’ means any property 23
which— 24
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‘‘(1) is sold or exchanged by a qualified manu-1
facturer in connection with a qualified relocation of 2
manufacturing, and 3
‘‘(2) was used by such qualified manufacturer 4
in the trade or business of manufacturing any tan-5
gible personal property in the foreign country from 6
which such manufacturing is being relocated. 7
‘‘(c) O
THERTERMS.—Terms used in this section 8
which are also used in subsection (n) of section 168 shall 9
have the same meaning when used in this section as when 10
used in such subsection.’’. 11
(2) C
LERICAL AMENDMENT .—The table of sec-12
tions for part III of subchapter B of chapter 1 of 13
such Code is amended by inserting after the item re-14
lating to section 139I the following new item: 15
‘‘Sec. 139J. Exclusion of gain on disposition of property in connection with
qualified relocation of manufacturing.’’.
(c) EFFECTIVEDATES.— 16
(1) A
CCELERATED DEPRECIATION .—The 17
amendment made by subsection (a) shall apply to 18
property placed in service after the date of the en-19
actment of this Act. 20
(2) E
XCLUSION OF GAIN .—The amendments 21
made by subsection (b) shall apply to sales and ex-22
changes after the date of the enactment of this Act. 23
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SEC. 3. PERMANENT FULL EXPENSING FOR QUALIFIED 1
PROPERTY. 2
(a) I
NGENERAL.—Paragraph (6) of section 168(k) 3
of the Internal Revenue Code of 1986 is amended to read 4
as follows: 5
‘‘(6) A
PPLICABLE PERCENTAGE .—For purposes 6
of this subsection, the term ‘applicable percentage’ 7
means, in the case of property placed in service (or, 8
in the case of a specified plant described in para-9
graph (5), a plant which is planted or grafted) after 10
September 27, 2017, 100 percent.’’. 11
(b) C
ONFORMINGAMENDMENTS.— 12
(1) Section 168(k) of the Internal Revenue 13
Code of 1986 is amended— 14
(A) in paragraph (2)— 15
(i) in subparagraph (A)— 16
(I) in clause (i)(V), by inserting 17
‘‘and’’ at the end; 18
(II) in clause (ii), by striking 19
‘‘clause (ii) of subparagraph (E), 20
and’’ and inserting ‘‘clause (i) of sub-21
paragraph (E).’’; and 22
(III) by striking clause (iii); 23
(ii) in subparagraph (B)— 24
(I) in clause (i)— 25
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(aa) by striking subclauses 1
(II) and (III); and 2
(bb) by redesignating sub-3
clauses (IV) through (VI) as sub-4
clauses (II) through (IV), respec-5
tively; 6
(II) by striking clause (ii); and 7
(III) by redesignating clauses 8
(iii) and (iv) as clauses (ii) and (iii), 9
respectively; 10
(iii) in subparagraph (C)— 11
(I) in clause (i), by striking ‘‘and 12
subclauses (II) and (III) of subpara-13
graph (B)(i)’’; and 14
(II) in clause (ii), by striking 15
‘‘subparagraph (B)(iii)’’ and inserting 16
‘‘subparagraph (B)(ii)’’; and 17
(iv) in subparagraph (E)— 18
(I) by striking clause (i); and 19
(II) by redesignating clauses (ii) 20
and (iii) as clauses (i) and (ii), respec-21
tively; and 22
(B) in paragraph (5)(A), by striking 23
‘‘planted before January 1, 2027, or is grafted 24
before such date to a plant that has already 25
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been planted,’’ and inserting ‘‘planted or graft-1
ed’’. 2
(2) Section 460(c)(6)(B) of such Code is 3
amended by striking ‘‘which’’ and all that follows 4
through the period and inserting ‘‘which has a recov-5
ery period of 7 years or less.’’. 6
(c) E
FFECTIVEDATE.—The amendments made by 7
this section shall take effect as if included in section 8
13201 of Public Law 115–97. 9
Æ
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