SEC. 2. TAX INCENTIVES FOR RELOCATING MANUFAC-
TURING TO THE UNITED STATES. 
(a) ACCELERATED DEPRECIATION
FOR NONRESI-
DENTIAL 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 NONRESI-
DENTIAL 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 PROP-
ERTY.—For purposes of this subsection, the term 
‘qualified nonresidential real property’ means non-
residential 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 manufac-
turing. 
‘‘(4) QUALIFIED
MANUFACTURER.—For pur-
poses of this subsection, the term ‘qualified manu-
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facturer’ means any person engaged in the trade or 
business of manufacturing any tangible personal 
property. 
‘‘(5) QUALIFIED
RELOCATION
OF
MANUFAC-
TURING.—For purposes of this subsection— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
relocation of manufacturing’ means, with re-
spect to any qualified manufacturer, the reloca-
tion of the manufacturing of any tangible per-
sonal property from a foreign country to the 
United States. 
‘‘(B) RELOCATION OF PROPERTY NOT RE-
QUIRED.—For purposes of subparagraph (A), 
manufacturing shall not fail to be treated as re-
located merely because property used in such 
manufacturing was not relocated. 
‘‘(C) RELOCATION
OF
NOT
LESS
THAN 
EQUIVALENT
PRODUCTIVE
CAPACITY
RE-
QUIRED.—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 quali-
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fied manufacturer is not less than the reduction 
in the units of production of such property in 
such foreign country by such qualified manufac-
turer. 
‘‘(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 PROP-
ERTY 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 PROP-
ERTY IN CONNECTION WITH QUALIFIED RE-
LOCATION OF MANUFACTURING. 
‘‘(a) IN GENERAL.—In the case of a qualified manu-
facturer, gross income shall not include gain from the sale 
or exchange of qualified relocation disposition property. 
‘‘(b) QUALIFIED RELOCATION DISPOSITION PROP-
ERTY.—For purposes of this section, the term ‘qualified 
relocation disposition property’ means any property 
which— 
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‘‘(1) is sold or exchanged by a qualified manu-
facturer in connection with a qualified relocation of 
manufacturing, and 
‘‘(2) was used by such qualified manufacturer 
in the trade or business of manufacturing any tan-
gible 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 sec-
tions for part III of subchapter B of chapter 1 of 
such Code is amended by inserting after the item re-
lating 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 en-
actment of this Act. 
(2) EXCLUSION
OF
GAIN.—The amendments 
made by subsection (b) shall apply to sales and ex-
changes after the date of the enactment of this Act. 
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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 para-
graph (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 sub-
paragraph (E).’’; and 
(III) by striking clause (iii); 
(ii) in subparagraph (B)— 
(I) in clause (i)— 
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(aa) by striking subclauses 
(II) and (III); and 
(bb) by redesignating sub-
clauses (IV) through (VI) as sub-
clauses (II) through (IV), respec-
tively; 
(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 subpara-
graph (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), respec-
tively; 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 
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