I 

118TH CONGRESS 

1ST SESSION H. R. 2571 

To amend the Internal Revenue Code of 1986 to provide a tax credit for 

certain expenses of moving manufacturing equipment from China to 

the United States, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

APRIL 10, 2023 

Mr. POSEY 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 

a tax credit for certain expenses of moving manufacturing equipment from China to the United States, 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 ‘‘Reshoring American 

5 Manufacturing Act of 2023’’ or as the ‘‘RAM Act of 

6 2023’’. 


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1 SEC. 2. CREDIT FOR CERTAIN EXPENSES OF MOVING MAN2 UFACTURING EQUIPMENT FROM CHINA TO 

3 THE UNITED STATES. 

4 (a) IN GENERAL.—Subpart D of part IV of sub5 chapter A of chapter 1 of the Internal Revenue Code of 

6 1986 is amended by adding at the end the following new 

7 section: 

8 ‘‘SEC. 45BB. MANUFACTURING RESHORING CREDIT. 

9 ‘‘(a) IN GENERAL.—For purposes of section 38, the 

10 manufacturing reshoring credit for any taxable year is the 

11 applicable percentage of the eligible reshoring expenses 

12 paid or incurred by the taxpayer during such taxable year. 

13 ‘‘(b) LIMITATION.—The credit determined under sub14 section (a) with respect to any taxpayer for any taxable 

15 year shall not exceed $25,000,000. 

16 ‘‘(c) APPLICABLE PERCENTAGE.—For purposes of 

17 this section, the term ‘applicable percentage’ means— 

18 ‘‘(1) in the case of any taxable year beginning 

19 in 2023 or 2024, 100 percent, 

20 ‘‘(2) in the case of any taxable year beginning 

21 in 2025, 80 percent, and 

22 ‘‘(3) in the case of any taxable year beginning 

23 in 2026, 60 percent. 

24 ‘‘(d) ELIGIBLE RESHORING EXPENSES.—For pur25 poses of this section— 


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1 ‘‘(1) IN GENERAL.—The term ‘eligible reshoring 

2 expenses’ means, with respect to any taxpayer, 

3 amounts paid or incurred by such taxpayer for the 

4 transportation (including any import duties, fees, or 

5 tariffs imposed with respect to such transportation) 

6 of qualified manufacturing equipment from China to 

7 the United States. 

8 ‘‘(2) QUALIFIED MANUFACTURING EQUIP9 MENT.—The term ‘qualified manufacturing equip10 ment’ means, with respect to any taxpayer, manu11 facturing equipment owned by such taxpayer 

12 which— 

13 ‘‘(A) before the transportation referred to 

14 in paragraph (1) was used by such taxpayer to 

15 manufacture tangible property in China, and 

16 ‘‘(B) after the transportation referred to in 

17 paragraph (1) is used by such taxpayer to man18 ufacture tangible property in the United States. 

19 ‘‘(e) RECAPTURE.—If any qualified manufacturing 

20 equipment with respect to which a credit was allowed 

21 under this section is transported outside the United States 

22 (after transportation to the United States as described in 

23 subsection (d)) during the 3-year period beginning on the 

24 date (after such transportation) on which such property 

25 is placed in service by the taxpayer in the United States, 


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1 the tax imposed under this chapter on such taxpayer for 

2 the taxable year which includes the date on which such 

3 property is so transported outside the United States shall 

4 be increased by the amount of the credit determined under 

5 this section with respect to such property. 

6 ‘‘(f) SPECIAL RULES.— 

7 ‘‘(1) DENIAL OF DOUBLE BENEFIT.—Any de8 duction or credit allowed under this title (other than 

9 this section) with respect to any eligible reshoring 

10 expenses shall be reduced by the amount of the cred11 it determined under this section. 

12 ‘‘(2) AGGREGATION RULE.—For purposes of 

13 the dollar limitation imposed under subsection (b), 

14 all members of the same controlled group of corpora15 tions (within the meaning of section 267(f)) and all 

16 persons under common control (within the meaning 

17 of section 52(b) but determined by treating an inter18 est of more than 50 percent as a controlling inter19 est) shall be treated as 1 person and such dollar lim20 itation shall be allocated in such manner as the Sec21 retary may provide. 

22 ‘‘(3) ELECTION TO NOT HAVE SECTION

23 APPLY.—No credit shall be determined under sub24 section (a) with respect to any taxpayer for any tax25 able year if such taxpayer make an election under 


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1 this paragraph (at such time and in such manner as 

2 the Secretary may provide) to have such subsection 

3 not apply for such taxable year. 

4 ‘‘(g) TERMINATION.—No credit shall be determined 

5 under this section for any taxable year beginning after De6 cember 31, 2026.’’. 

7 (b) CREDIT ALLOWED AS PART OF GENERAL BUSI8 NESS CREDIT.—Section 38(b) of such Code is amended 

9 by striking ‘‘plus’’ at the end of paragraph (40), by strik10 ing the period at the end of paragraph (41) and inserting 

11 ‘‘, plus’’, and by adding at the end the following new para12 graph: 

13 ‘‘(42) the manufacturing reshoring credit deter14 mined under section 45BB(a).’’. 

15 (c) CLERICAL AMENDMENT.—The table of sections 

16 for subpart D of part IV of subchapter A of chapter 1 

17 of such Code is amended by adding at the end the fol18 lowing new item: 

‘‘Sec. 45BB. Manufacturing reshoring credit.’’. 

19 (d) EFFECTIVE DATE.—The amendments made by 

20 this section shall apply to amounts paid or incurred after 

21 the date of the enactment of this Act, in taxable years 

22 ending after such date. 

Æ 


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