I 

118TH CONGRESS 

1ST SESSION H. R. 947 

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 

FEBRUARY 9, 2023 

Mr. ROY (for himself, Mr. BISHOP of North Carolina, Mr. GOSAR, and Mr. 

BABIN) 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. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Bring Entrepreneurial 

5 Advancements To Consumers Here In North America 

6 Act’’. 


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1 SEC. 2. TAX INCENTIVES FOR RELOCATING MANUFAC2 TURING TO THE UNITED STATES. 

3 (a) ACCELERATED DEPRECIATION FOR NONRESI4 DENTIAL REAL PROPERTY.—Section 168 of the Internal 

5 Revenue Code of 1986 is amended by adding at the end 

6 the following new subsection: 

7 ‘‘(n) ACCELERATED DEPRECIATION FOR NONRESI8 DENTIAL REAL PROPERTY ACQUIRED IN CONNECTION

9 WITH THE RELOCATION OF MANUFACTURING TO THE

10 UNITED STATES.— 

11 ‘‘(1) TREATMENT AS 20-YEAR PROPERTY.—For 

12 purposes of this section, qualified nonresidential real 

13 property shall be treated as 20-year property. 

14 ‘‘(2) APPLICATION OF BONUS DEPRECIATION.— 

15 For application of bonus depreciation to qualified 

16 nonresidential real property, see subsection (k). 

17 ‘‘(3) QUALIFIED NONRESIDENTIAL REAL PROP18 ERTY.—For purposes of this subsection, the term 

19 ‘qualified nonresidential real property’ means non20 residential real property placed in service in the 

21 United States by a qualified manufacturer if such 

22 property is acquired by such qualified manufacturer 

23 in connection with a qualified relocation of manufac24 turing. 

25 ‘‘(4) QUALIFIED MANUFACTURER.—For pur26 poses of this subsection, the term ‘qualified manuVerDate Sep 11 2014 05:13 Mar 07, 2023 Jkt 039200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\H947.IH H947

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1 facturer’ means any person engaged in the trade or 

2 business of manufacturing any tangible personal 

3 property. 

4 ‘‘(5) QUALIFIED RELOCATION OF MANUFAC5 TURING.—For purposes of this subsection— 

6 ‘‘(A) IN GENERAL.—The term ‘qualified 

7 relocation of manufacturing’ means, with re8 spect to any qualified manufacturer, the reloca9 tion of the manufacturing of any tangible per10 sonal property from a foreign country to the 

11 United States. 

12 ‘‘(B) RELOCATION OF PROPERTY NOT RE13 QUIRED.—For purposes of subparagraph (A), 

14 manufacturing shall not fail to be treated as re15 located merely because property used in such 

16 manufacturing was not relocated. 

17 ‘‘(C) RELOCATION OF NOT LESS THAN

18 EQUIVALENT PRODUCTIVE CAPACITY RE19 QUIRED.—For purposes of subparagraph (A), 

20 manufacturing shall not be treated as relocated 

21 unless the property manufactured in the United 

22 States is substantially identical to the property 

23 previously manufactured in a foreign country 

24 and the increase in the units of production of 

25 such property in the United States by the qualiVerDate Sep 11 2014 05:13 Mar 07, 2023 Jkt 039200 PO 00000 Frm 00003 Fmt 6652 Sfmt 6201 E:\BILLS\H947.IH H947

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1 fied manufacturer is not less than the reduction 

2 in the units of production of such property in 

3 such foreign country by such qualified manufac4 turer. 

5 ‘‘(6) APPLICATION TO POSSESSIONS OF THE

6 UNITED STATES.—For purposes of this subsection, 

7 the term ‘United States’ includes any possession of 

8 the United States.’’. 

9 (b) EXCLUSION OF GAIN ON DISPOSITION OF PROP10 ERTY IN CONNECTION WITH QUALIFIED RELOCATION OF

11 MANUFACTURING.— 

12 (1) IN GENERAL.—Part III of subchapter B of 

13 chapter 1 of such Code is amended by inserting 

14 after section 139I the following new section: 

15 ‘‘SEC. 139J. EXCLUSION OF GAIN ON DISPOSITION OF PROP16 ERTY IN CONNECTION WITH QUALIFIED RE17 LOCATION OF MANUFACTURING. 

18 ‘‘(a) IN GENERAL.—In the case of a qualified manu19 facturer, gross income shall not include gain from the sale 

20 or exchange of qualified relocation disposition property. 

21 ‘‘(b) QUALIFIED RELOCATION DISPOSITION PROP22 ERTY.—For purposes of this section, the term ‘qualified 

23 relocation disposition property’ means any property 

24 which— 


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1 ‘‘(1) is sold or exchanged by a qualified manu2 facturer in connection with a qualified relocation of 

3 manufacturing, and 

4 ‘‘(2) was used by such qualified manufacturer 

5 in the trade or business of manufacturing any tan6 gible personal property in the foreign country from 

7 which such manufacturing is being relocated. 

8 ‘‘(c) OTHER TERMS.—Terms used in this section 

9 which are also used in subsection (n) of section 168 shall 

10 have the same meaning when used in this section as when 

11 used in such subsection.’’. 

12 (2) CLERICAL AMENDMENT.—The table of sec13 tions for part III of subchapter B of chapter 1 of 

14 such Code is amended by inserting after the item re15 lating to section 139I the following new item: 

‘‘Sec. 139J. Exclusion of gain on disposition of property in connection with 

qualified relocation of manufacturing.’’. 

16 (c) EFFECTIVE DATES.— 

17 (1) ACCELERATED DEPRECIATION.—The 

18 amendment made by subsection (a) shall apply to 

19 property placed in service after the date of the en20 actment of this Act. 

21 (2) EXCLUSION OF GAIN.—The amendments 

22 made by subsection (b) shall apply to sales and ex23 changes after the date of the enactment of this Act. 


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1 SEC. 3. PERMANENT FULL EXPENSING FOR QUALIFIED 

2 PROPERTY. 

3 (a) IN GENERAL.—Paragraph (6) of section 168(k) 

4 of the Internal Revenue Code of 1986 is amended to read 

5 as follows: 

6 ‘‘(6) APPLICABLE PERCENTAGE.—For purposes 

7 of this subsection, the term ‘applicable percentage’ 

8 means, in the case of property placed in service (or, 

9 in the case of a specified plant described in para10 graph (5), a plant which is planted or grafted) after 

11 September 27, 2017, 100 percent.’’. 

12 (b) CONFORMING AMENDMENTS.— 

13 (1) Section 168(k) of the Internal Revenue 

14 Code of 1986 is amended— 

15 (A) in paragraph (2)— 

16 (i) in subparagraph (A)— 

17 (I) in clause (i)(V), by inserting 

18 ‘‘and’’ at the end; 

19 (II) in clause (ii), by striking 

20 ‘‘clause (ii) of subparagraph (E), 

21 and’’ and inserting ‘‘clause (i) of sub22 paragraph (E).’’; and 

23 (III) by striking clause (iii); 

24 (ii) in subparagraph (B)— 

25 (I) in clause (i)— 


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1 (aa) by striking subclauses 

2 (II) and (III); and 

3 (bb) by redesignating sub4 clauses (IV) through (VI) as sub5 clauses (II) through (IV), respec6 tively; 

7 (II) by striking clause (ii); and 

8 (III) by redesignating clauses 

9 (iii) and (iv) as clauses (ii) and (iii), 

10 respectively; 

11 (iii) in subparagraph (C)— 

12 (I) in clause (i), by striking ‘‘and 

13 subclauses (II) and (III) of subpara14 graph (B)(i)’’; and 

15 (II) in clause (ii), by striking 

16 ‘‘subparagraph (B)(iii)’’ and inserting 

17 ‘‘subparagraph (B)(ii)’’; and 

18 (iv) in subparagraph (E)— 

19 (I) by striking clause (i); and 

20 (II) by redesignating clauses (ii) 

21 and (iii) as clauses (i) and (ii), respec22 tively; and 

23 (B) in paragraph (5)(A), by striking 

24 ‘‘planted before January 1, 2027, or is grafted 

25 before such date to a plant that has already 


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1 been planted,’’ and inserting ‘‘planted or graft2 ed’’. 

3 (2) Section 460(c)(6)(B) of such Code is 

4 amended by striking ‘‘which’’ and all that follows 

5 through the period and inserting ‘‘which has a recov6 ery period of 7 years or less.’’. 

7 (c) EFFECTIVE DATE.—The amendments made by 

8 this section shall take effect as if included in section 

9 13201 of Public Law 115–97. 

Æ 


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