I 

114TH CONGRESS 

1ST SESSION H. R. 2524 

To amend the Internal Revenue Code of 1986 to increase the limitations 

for deductible new business expenditures and to consolidate provisions 

for start-up and organizational expenditures. 

IN THE HOUSE OF REPRESENTATIVES 

MAY 21, 2015 

Mr. BUCHANAN (for himself, Ms. LINDA T. SA ́NCHEZ of California, Mr. BLUMENAUER, Mr. RANGEL, Mr. RENACCI, Mr. KIND, Mr. THOMPSON of 

California, Mr. TIBERI, Mr. DOLD, Mr. NEAL, Mr. KELLY of Pennsylvania, Mr. REED, and Mr. PASCRELL) 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 increase 

the limitations for deductible new business expenditures 

and to consolidate provisions for start-up and organizational expenditures. 

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 ‘‘Support Our Start5 Ups Act’’. 


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1 SEC. 2. NEW BUSINESS EXPENDITURES. 

2 (a) IN GENERAL.—Subsections (a) and (b) of section 

3 195 of the Internal Revenue Code of 1986 are both 

4 amended by inserting ‘‘and organizational’’ after ‘‘start5 up’’ each place it appears. 

6 (b) ORGANIZATIONAL EXPENDITURES.—Subsection 

7 (c) of section 195 of such Code is amended by adding at 

8 the end the following new paragraph: 

9 ‘‘(3) ORGANIZATIONAL EXPENDITURES.—The 

10 term ‘organizational expenditures’ means any ex11 penditure which— 

12 ‘‘(A) is incident to the creation of a cor13 poration or a partnership, 

14 ‘‘(B) is chargeable to capital account, and 

15 ‘‘(C) is of a character which, if expended 

16 incident to the creation of a corporation or a 

17 partnership having a limited life, would be am18 ortizable over such life.’’. 

19 (c) DOLLAR AMOUNTS.—Clause (ii) of section 

20 195(b)(1)(A) of such Code is amended— 

21 (1) by striking ‘‘$5,000’’ and inserting 

22 ‘‘$20,000’’, and 

23 (2) by striking ‘‘$50,000’’ and inserting 

24 ‘‘$120,000’’. 


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1 (d) AMORTIZATION TREATMENT.—Subparagraph (B) 

2 of section 195(b)(1) of such Code, as amended by sub3 section (a), is amended to read as follows: 

4 ‘‘(B) the remainder of such start-up and 

5 organizational expenditures shall be charged to 

6 capital account and allowed as an amortization 

7 deduction determined by amortizing such ex8 penditures ratably over the 15-year period be9 ginning with the midpoint of the taxable year in 

10 which the active trade or business begins.’’. 

11 (e) CONFORMING AMENDMENTS.— 

12 (1) Section 195(b)(1) of such Code is amend13 ed— 

14 (A) by inserting ‘‘(or, in the case of a part15 nership, the partnership elects)’’ after ‘‘If a tax16 payer elects’’, and 

17 (B) by inserting ‘‘(or the partnership, as 

18 the case may be)’’ after ‘‘the taxpayer’’ in sub19 paragraph (A). 

20 (2) Section 195(b)(2) of such Code is amend21 ed— 

22 (A) by striking ‘‘AMORTIZATION PERIOD.— 

23 In any case’’ and inserting the following: ‘‘AM24 ORTIZATION PERIOD.— 

25 ‘‘(A) IN GENERAL.—In any case’’, and 


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1 (B) by adding at the end the following new 

2 subparagraph: 

3 ‘‘(B) SPECIAL PARTNERSHIP RULE.—In 

4 the case of a partnership, subparagraph (A) 

5 shall be applied at the partnership level.’’. 

6 (3) Section 195(b) of such Code is amended by 

7 striking paragraph (3). 

8 (4)(A) Part VIII of subchapter B of chapter 1 

9 of such Code is amended by striking section 248 

10 (and by striking the item relating to such section in 

11 the table of sections for such part). 

12 (B) Section 56(g)(4)(D)(ii) of such Code is 

13 amended by striking ‘‘Sections 173 and 248’’ and 

14 inserting ‘‘Section 173’’. 

15 (C) Section 170(b)(2)(C)(ii) of such Code is 

16 amended by striking ‘‘(except section 248)’’. 

17 (D) Section 312(n)(3) of such Code is amended 

18 by striking ‘‘Sections 173 and 248’’ and inserting 

19 ‘‘Section 173’’. 

20 (E) Section 535(b)(3) of such Code is amended 

21 by striking ‘‘(except section 248)’’. 

22 (F) Section 545(b)(3) of such Code is amended 

23 by striking ‘‘(except section 248)’’. 

24 (G) Section 834(c)(7) of such Code is amended 

25 by striking ‘‘(except section 248)’’. 


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1 (H) Section 852(b)(2)(C) of such Code is 

2 amended by striking ‘‘(except section 248)’’. 

3 (I) Section 857(b)(2)(A) of such Code is 

4 amended by striking ‘‘(except section 248)’’. 

5 (J) Section 1363(b) of such Code is amended 

6 by inserting ‘‘and’’ at the end of paragraph (2), by 

7 striking paragraph (3), and by redesignating para8 graph (4) as paragraph (3). 

9 (K) Section 1375(b)(1)(B)(i) of such Code is 

10 amended by striking ‘‘(other than the deduction al11 lowed by section 248, relating to organization ex12 penditures)’’. 

13 (5) Part I of subchapter K of chapter 1 of such 

14 Code is amended by striking section 709 (and by 

15 striking the item relating to such section in the table 

16 of sections for such part). 

17 (6) The heading of section 195 of such Code 

18 (and the item relating to such section in the table 

19 of sections for part VI of subchapter B of chapter 

20 1 of such Code) are each amended by inserting ‘‘and 

21 organizational’’ after ‘‘Start-up’’. 

22 (f) EFFECTIVE DATE.—The amendments made by 

23 this section shall apply to expenses paid or incurred in 

24 taxable years beginning after December 31, 2015. 

Æ 


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