not apply to specified research or experimental ex-
penditures to which this section applies. 
‘‘(2) COORDINATION
WITH
BASIS
ADJUSTMENT 
RULES.—Section 1016(a)(14) shall be applied by sub-
stituting ‘an amortization deduction under section 
174(a)’ for ‘deductions as deferred expenses under sec-
tion 174(b)(1)’. 
‘‘(3) COORDINATION WITH LONG-TERM CONTRACT 
RULES.—For purposes of determining percentage of 
completion under section 460(b)(1)(A), the amortiza-
tion deduction under subsection (a) shall be taken 
into account as a cost allocated to the contract.’’. 
(d) CONFORMING AMENDMENTS.— 
(1) Section 13206 of Public Law 115-97 is 
amended by striking subsection (b) (relating to 
change in method of accounting). 
(2) The table of sections for part VI of sub-
chapter B of chapter 1 is amended by inserting after 
the item relating to section 174 the following new 
item: 
‘‘Sec. 174A. Temporary rules for research and experimental expenditures.’’. 
(e) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendments made by this sec-
tion shall apply to amounts paid or incurred in tax-
able years beginning after December 31, 2021. 
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(2) REPEAL OF SUPERCEDED CHANGE IN METH-
OD OF ACCOUNTING RULES.—The amendment made 
by subsection (d)(1) shall take effect as if included in 
Public Law 115-97. 
(f) TRANSITION RULES.— 
(1) 
ELECTION
REGARDING
TREATMENT
AS 
CHANGE IN METHOD OF ACCOUNTING.—In the case of 
any taxpayer which (as of the date of the enactment 
of this Act) had adopted a method of accounting pro-
vided by section 174 of the Internal Revenue Code of 
1986 (as in effect prior to the amendments made by 
this section) for the taxpayer’s first taxable year be-
ginning after December 31, 2021, and elects the ap-
plication of this paragraph— 
(A) the amendments made by this section 
shall be treated as a change in method of ac-
counting for purposes of section 481 of such 
Code, 
(B) such change shall be treated as initiated 
by the taxpayer for the taxpayer’s immediately 
succeeding taxable year, 
(C) such change shall be treated as made 
with the consent of the Secretary, and 
(D) such change shall be applied on a modi-
fied cut-off basis, taking into account for pur-
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poses of section 481(a) of such Code only the cap-
italized expenditures which were not allowed as 
an amortization deduction by reason of section 
174 prior to amendment by this Act for the tax-
payer’s first taxable year beginning after Decem-
ber 31, 2021. 
(2) ELECTION REGARDING 10-YEAR WRITEOFF.— 
(A) IN
GENERAL.—An eligible taxpayer 
which files, during the 1-year period beginning 
on the date of the enactment of this Act, an 
amended income tax return for the taxable year 
described in subparagraph (B)(ii) may elect the 
application of section 59(e) of the Internal Rev-
enue Code of 1986 with respect to qualified ex-
penditures described in section 59(e)(2)(B) of 
such Code with respect to such taxable year. 
Such election shall be filed with such amended 
income tax return and shall be effective only to 
the extent that such election would have been ef-
fective if filed with the original income tax re-
turn for such taxable year. 
(B) ELIGIBLE TAXPAYER.—For purposes of 
subparagraph (A), the term ‘‘eligible taxpayer’’ 
means any taxpayer which— 
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(i) does not elect the application of 
paragraph (1), and 
(ii) filed an income tax return for such 
taxpayer’s first taxable year beginning after 
December 31, 2021, before the earlier of— 
(I) the due date for such return, 
and 
(II) the date of the enactment of 
this Act. 
SEC. 102. EXTENSION OF ALLOWANCE FOR DEPRECIATION, 
AMORTIZATION, OR DEPLETION IN DETER-
MINING THE LIMITATION ON BUSINESS IN-
TEREST. 
(a) IN GENERAL.—Section 163(j)(8)(A)(v) is amended 
by striking ‘‘January 1, 2022’’ and inserting ‘‘January 1, 
2026’’. 
(b) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendment made by this sec-
tion shall apply to taxable years beginning after De-
cember 31, 2022. 
(2) ELECTION
TO
APPLY
EXTENSION
RETRO-
ACTIVELY.—In the case of a taxpayer which elects (at 
such time and in such manner as the Secretary may 
provide) the application of this paragraph, para-
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graph (1) shall be applied by substituting ‘‘December 
31, 2021’’ for ‘‘December 31, 2022’’. 
SEC. 103. EXTENSION OF 100 PERCENT BONUS DEPRECIA-
TION. 
(a) IN GENERAL.—Section 168(k)(6)(A) is amended— 
(1) in clause (i)— 
(A) by striking ‘‘2023’’ and inserting 
‘‘2026’’, and 
(B) by adding ‘‘and’’ at the end, and 
(2) by striking clauses (ii), (iii), and (iv), and 
redesignating clause (v) as clause (ii). 
(b) PROPERTY WITH LONGER PRODUCTION PERI-
ODS.—Section 168(k)(6)(B) is amended— 
(1) in clause (i)— 
(A) by striking ‘‘2024’’ and inserting 
‘‘2027’’, and 
(B) by adding ‘‘and’’ at the end, and 
(2) by striking clauses (ii), (iii), and (iv), and 
redesignating clause (v) as clause (ii). 
(c) PLANTS BEARING FRUITS AND NUTS.—Section 
168(k)(6)(C) is amended— 
(1) in clause (i)— 
(A) by striking ‘‘2023’’ and inserting 
‘‘2026’’, and 
(B) by adding ‘‘and’’ at the end, and 
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(2) by striking clauses (ii), (iii), and (iv), and 
redesignating clause (v) as clause (ii). 
(d) EFFECTIVE DATES.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendments made by this sec-
tion shall apply to property placed in service after 
December 31, 2022. 
(2) PLANTS BEARING FRUITS AND NUTS.—The 
amendments made by subsection (c) shall apply to 
specified plants planted or grafted after December 31, 
2022. 
TITLE II—SUPPLY CHAIN 
SECURITY 
SEC. 
201. 
TERMINATION 
OF 
HAZARDOUS 
SUBSTANCE 
SUPERFUND FINANCING RATE. 
(a) IN GENERAL.—Section 4611 (as amended by sec-
tion 13601 of Public Law 117–169) is amended by inserting 
after subsection (d) the following new subsection: 
‘‘(e) 
APPLICATION
OF
HAZARDOUS
SUBSTANCE 
SUPERFUND FINANCING RATE.—The Hazardous Substance 
Superfund financing rate under this section shall not apply 
after December 31, 2022.’’. 
(b) TERMINATION OF AUTHORITY FOR ADVANCES.— 
Section 9507(d)(3)(B) (as so amended) is amended— 
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(1) by striking ‘‘December 31, 2032’’ and insert-
ing ‘‘the date of the enactment of the Build It in 
America Act’’, and 
(2) by striking ‘‘on or before such date’’ and in-
serting ‘‘as soon as practicable thereafter’’. 
(c) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendment made by sub-
section (a) shall take effect on January 1, 2023. 
(2) TERMINATION
OF
AUTHORITY
FOR
AD-
VANCES.—The amendments made by subsection (b) 
shall take effect on the date of the enactment of this 
Act. 
SEC. 202. ELECTION TO DETERMINE FOREIGN INCOME 
TAXES PAID OR ACCRUED TO CERTAIN WEST-
ERN HEMISPHERE COUNTRIES WITHOUT RE-
GARD TO CERTAIN REGULATIONS. 
(a) ELECTION WITH RESPECT TO DETERMINING CER-
TAIN FOREIGN INCOME TAXES.—In the case of any tax-
payer which elects (at such time and in such manner as 
the Secretary may provide) the application of this sub-
section, the determination of whether any Western Hemi-
sphere tax paid or accrued by such taxpayer is an income, 
war profits, or excess profits tax for purposes of any provi-
sion of the Internal Revenue Code of 1986 shall be made 
without regard to any specified regulation. 
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(b) SEPARATE ELECTION WITH RESPECT TO ALLOCA-
TION AND APPORTIONMENT OF FOREIGN INCOME TAXES 
RELATING TO DISREGARDED PAYMENTS FROM CERTAIN 
DISREGARDED ENTITIES.— 
(1) IN GENERAL.—If the owner of any specified 
disregarded entity elects (at such time and in such 
manner as the Secretary may provide) the applica-
tion of this subsection with respect to such entity, 
then for purposes of allocating and apportioning any 
foreign income taxes (as defined in section 986(a)(4) 
of the Internal Revenue Code of 1986 and determined 
after the application of subsection (a) of this section) 
paid or accrued by reason of any remittance made by 
such entity to such owner during the applicable pe-
riod, any items of foreign gross income included by 
reason of the receipt of such remittance shall be as-
signed to a category based on current and accumu-
lated earnings and profits of such entity (in lieu of 
being assigned on the basis of the tax book value 
method described in a specified regulation). 
(2) SPECIFIED DISREGARDED ENTITY.—For pur-
poses of this subsection, the term ‘‘specified dis-
regarded entity’’ means any entity (including any 
trade or business) if— 
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(A) such entity is disregarded as an entity 
separate from its owner for purposes of applying 
chapter 1 of the Internal Revenue Code of 1986, 
(B) such entity is created or organized in a 
possession of the United States or a foreign coun-
try described in subsection (d)(1)(B), 
(C) at all times after December 31, 2019 
(or, if later, the date on which such entity is cre-
ated or organized) substantially all of the income 
of such entity is derived from trades or busi-
nesses conducted in the possession or country re-
ferred to in subparagraph (B), and 
(D) at all times after the date on which 
such entity is created or organized, such entity 
maintains separate books and records. 
(c) APPLICATION TO DEEMED PAID CREDIT.—In the 
case of any tax paid or accrued by a controlled foreign cor-
poration and deemed to have been paid by a United States 
shareholder under section 960 of the Internal Revenue Code 
of 1986— 
(1) any election under subsection (a) or (b) shall 
be made by such controlled foreign corporation and 
shall be binding on all United States shareholders of 
such controlled foreign corporation, and 
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(2) the applicable period under subsection (d) 
shall be determined with respect to the taxable years 
of such controlled foreign corporation. 
(d) WESTERN HEMISPHERE TAX.—For purposes of 
this section— 
(1) IN
GENERAL.—The term ‘‘Western Hemi-
sphere tax’’ means any tax which is paid or accrued 
for a taxable year which is in the applicable period 
to— 
(A) any possession of the United States, or 
(B) any foreign country (other than Cuba 
and Venezuela) which is located in North, Cen-
tral, or South America (including the West In-
dies). 
(2) APPLICABLE PERIOD.—The term ‘‘applicable 
period’’ means— 
(A) in the case of any election made under 
subsection (a), all taxable years beginning after 
December 31, 2021, and before January 1, 2027, 
and 
(B) in the case of any election made under 
subsection (b), all taxable years beginning after 
December 31, 2019, and before January 1, 2027. 
(3) DETERMINATION BASED ON TAXABLE YEAR 
FOR WHICH TAX ACTUALLY PAID OR ACCRUED.—The 
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determination of the taxable year for which any tax 
is paid or accrued for purposes of determining wheth-
er a foreign tax is paid or accrued for a taxable year 
which is in the applicable period shall be made with-
out regard to any taxable year with respect to which 
such tax is deemed to have been paid under section 
904(c) or 960 of the Internal Revenue Code of 1986. 
(e) SPECIFIED REGULATION.—For purposes of this 
section, the term ‘‘specified regulation’’ means— 
(1) Treasury Regulations relating to ‘‘Guidance 
Related to the Foreign Tax Credit; Clarification of 
Foreign-Derived Intangible Income’’ (87 Fed. Reg. 
276; published on January 4, 2022), 
(2) proposed Treasury Regulations relating to 
‘‘Guidance Related to the Foreign Tax Credit’’ (87 
Fed. Reg. 71271; published on November 22, 2022), 
and 
(3) any regulation or other guidance published 
after January 4, 2022, to the extent that such regula-
tion or other guidance is substantially similar to, or 
predicated upon, any portion of the regulations re-
ferred to in paragraph (1) or (2). 
In the case of any regulation or other guidance which is 
published after the date of the enactment of this Act and 
any portion of which is described in paragraph (3), the Sec-
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retary shall identify such regulation or guidance (or por-
tion thereof) as not applying with respect to taxpayers 
which have elected the application of subsection (a) or (b), 
as the case may be. 
(f) SECRETARY.—For purposes of this section, the term 
‘‘Secretary’’ means the Secretary of the Treasury or the Sec-
retary’s delegate. 
SEC. 203. IMPOSITION OF TAX ON THE ACQUISITION OF 
UNITED STATES AGRICULTURAL INTERESTS 
BY DISQUALIFIED PERSONS. 
(a) IN GENERAL.—Subtitle D is amended by inserting 
after chapter 50A the following new chapter: 
‘‘CHAPTER 50B—ACQUISITION OF UNITED 
STATES 
AGRICULTURAL 
INTERESTS 
BY DISQUALIFIED PERSONS 
‘‘Sec. 5000E. Imposition of tax on acquisition of United States agricultural in-
terests by disqualified persons. 
‘‘SEC. 5000E. IMPOSITION OF TAX ON ACQUISITION OF 
UNITED STATES AGRICULTURAL INTERESTS 
BY DISQUALIFIED PERSONS. 
‘‘(a) IN GENERAL.—In the case of any acquisition of 
any United States agricultural interest by any disqualified 
person, there is hereby imposed on such person a tax equal 
to 60 percent of the amount paid for such interest. 
‘‘(b) DISQUALIFIED PERSON.—For purposes of this 
section— 
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tion referred to in clause (i), any person 
which— 
‘‘(I) is described in subparagraph 
(A), (B), or (C) of paragraph (1), and 
‘‘(II) 10-percent controls such cor-
poration. 
‘‘(c) PRORATED TAX ON ACQUISITIONS BY ENTITIES 
NOT MORE THAN 50 PERCENT CONTROLLED BY DISQUALI-
FIED PERSONS.— 
‘‘(1) IN GENERAL.—In the case of any disquali-
fied person described in subsection (b)(1)(D) with re-
spect to which persons described in subparagraphs 
(A), (B), or (C) of subsection (b)(1) do not (in the ag-
gregate) control such disqualified person, subsection 
(a) shall be applied by substituting ‘the applicable 
percentage of the amount’ for ‘the amount’. 
‘‘(2) APPLICABLE
PERCENTAGE.—For purposes 
of this section, the term ‘applicable percentage’ means, 
with respect to any disqualified person to which 
paragraph (1) applies, the highest percentage which 
could be substituted for ‘50 percent’ both places it ap-
pears in section 954(d)(3) without causing persons 
described in subparagraph (A), (B), or (C) of sub-
section (b)(1) (in the aggregate) to control (deter-
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mined by taking into account such substitution) such 
disqualified person. 
‘‘(d) CONTROL.—For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘control’ has the 
meaning given such term under section 954(d)(3), de-
termined by treating the rules of section 958(a)(2) as 
applying to both foreign and domestic corporations, 
partnerships, trusts, and estates. 
‘‘(2) 10-PERCENT CONTROL.—The term ‘10-per-
cent control’ means control (as defined in paragraph 
(1)), determined by substituting ‘10 percent’ for ‘50 
percent’ both places it appears in section 954(d)(3). 
‘‘(e) UNITED STATES AGRICULTURAL INTEREST.—For 
purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘United States ag-
ricultural interest’ has the meaning which would be 
given the term ‘United States real property interest’ 
by section 897(c) if— 
‘‘(A) paragraph (1)(A)(i) were applied by 
substituting ‘an interest in agricultural land’ for 
‘an interest in real property’ and all that fol-
lows, 
‘‘(B) paragraph (1)(A)(ii) were applied by 
substituting ‘such corporation was not a United 
States real property holding corporation at the 
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time of acquisition’ for ‘such corporation’ and 
all that follows, 
‘‘(C) paragraph (1)(B) did not apply, and 
‘‘(D) paragraph (3) were applied by sub-
stituting ‘at the time of acquisition’ for ‘at some 
time during the shorter of the periods described 
in paragraph (1)(A)(ii)’. 
‘‘(2) AGRICULTURAL
LAND.—For purposes of 
paragraph (1), the term ‘agricultural land’ means— 
‘‘(A) agricultural land as defined in section 
9 of the Agricultural Foreign Investment Disclo-
sure Act of 1978 (7 U.S.C. 3508), and 
‘‘(B) land located in one or more States and 
used for livestock production purposes (deter-
mined under rules similar to the rules that 
apply under such section 9).’’. 
(b) REPORTING REQUIREMENTS.— 
(1) IN GENERAL.—Subpart B of part III of sub-
chapter A of chapter 61 is amended by adding at the 
end the following new section: 
‘‘SEC. 6050AA. RETURNS RELATING TO ACQUISITION OF 
UNITED STATES AGRICULTURAL INTERESTS 
BY DISQUALIFIED PERSONS. 
‘‘(a) IN GENERAL.—The required reporting person, 
with respect to any acquisition of any United States agri-
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cultural interest by a presumptively disqualified person to 
which section 5000E(a) applies, shall make a return at such 
time as the Secretary may provide setting forth— 
‘‘(1) the name, address, and TIN of such pre-
sumptively disqualified person, 
‘‘(2) a description of such United States agricul-
tural interest (including the street address, if applica-
ble), and 
‘‘(3) the amount paid for such United States ag-
ricultural interest. 
‘‘(b) STATEMENT TO BE FURNISHED TO PRESUMP-
TIVELY DISQUALIFIED PERSON.—Every person required to 
make a return under subsection (a) shall furnish, at such 
time as the Secretary may provide, to each presumptively 
disqualified person whose name is required to be set forth 
in such return a written statement showing— 
‘‘(1) the name and address of the information 
contact of the required reporting person, and 
‘‘(2) the information described in paragraphs 
(1), (2), and (3) of subsection (a) which relates to 
such disqualified person. 
‘‘(c) REQUIRED REPORTING PERSON.—For purposes 
of this section, the term ‘required reporting person’ means, 
with respect to any acquisition of any United States agri-
cultural interest— 
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‘‘(1) the person (including any attorney or title 
company) responsible for closing the transaction in 
which such United States agricultural interest is ac-
quired, or 
‘‘(2) if no one is responsible for closing such 
transaction (or in such other cases as the Secretary 
may provide), the transferor of such United States ag-
ricultural interest. 
‘‘(d) PRESUMPTIVELY DISQUALIFIED PERSON.—For 
purposes of this section, the term ‘presumptively disquali-
fied person’ means any person unless such person furnishes 
to the required reporting person an affidavit by the such 
person stating, under penalty of perjury, that such person 
is not a disqualified person (as defined in section 
5000E(b)). 
‘‘(e) REQUIREMENT TO REQUEST AFFIDAVIT.—If the 
required reporting person, with respect to any acquisition 
of any United States agricultural interest, has not, as of 
the time of such acquisition, been furnished the affidavit 
described in subsection (d) by the acquirer of such interest, 
such required reporting person shall furnish to such 
acquirer, at such time, a written statement informing such 
acquirer of the required reporting person’s obligation to 
make the return described in subsection (a) with respect to 
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such acquisition and including such other information as 
the Secretary may require. 
‘‘(f) UNITED STATES AGRICULTURAL INTEREST.—For 
purposes of this section, the term ‘United States agricul-
tural interest’ has the meaning given such term in section 
5000E.’’. 
(2) PENALTIES.—Section 6724(d) is amended— 
(A) in paragraph (1)(B), by striking ‘‘or’’ 
at the end of clause (xxvii), by striking ‘‘and’’ at 
the end of clause (xxviii) and inserting ‘‘or’’, and 
by adding at the end the following new clause: 
‘‘(xxix) section 6050AA(a) (relating to 
returns relating to acquisition of United 
States agricultural interests by disqualified 
persons), and’’, and 
(B) in paragraph (2), by striking ‘‘or’’ at 
the end of subparagraph (KK), by striking the 
period at the end of subparagraph (LL) and in-
serting ‘‘, or’’, and by inserting after subpara-
graph (LL) the following new subparagraph: 
‘‘(MM) subsection (b) or (e) of section 
6055AA (relating to statements relating to acqui-
sition of United States agricultural interests by 
disqualified persons).’’. 
(c) CLERICAL AMENDMENTS.— 
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