I 
119TH CONGRESS 
1ST SESSION H. R. 1328 
To amend the Internal Revenue Code of 1986 to establish the critical supply 
chains reshoring investment tax credit. 
IN THE HOUSE OF REPRESENTATIVES 
FEBRUARY 13, 2025 
Ms. MALLIOTAKIS
(for herself, Mr. PANETTA, Mr. BUCHANAN, Ms. 
VELA´ZQUEZ, Mr. KELLY of Pennsylvania, Mr. HERNA´NDEZ, and Mr. 
LAWLER) introduced the following bill; which was referred to the Com-
mittee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to establish 
the critical supply chains reshoring investment tax credit. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Supply Chain Security 
and Growth Act of 2025’’. 
SEC. 2. CRITICAL SUPPLY CHAINS RESHORING INVEST-
MENT CREDIT. 
(a) IN GENERAL.—Subpart E of part IV of sub-
chapter A of the Internal Revenue Code of 1986 is amend-
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ed by inserting after section 48E the following new sec-
tion: 
‘‘SEC. 48F. CRITICAL SUPPLY CHAINS RESHORING INVEST-
MENT CREDIT. 
‘‘(a) IN GENERAL.—For purposes of section 46, in 
the case of a qualifying taxpayer, the critical supply chains 
reshoring investment credit is an amount equal to 40 per-
cent of the qualified investment with respect to any critical 
supply chain facility placed in service during such taxable 
year. 
‘‘(b) DEFINITIONS AND SPECIAL RULES.—For pur-
poses of this section— 
‘‘(1) QUALIFYING TAXPAYER.— 
‘‘(A) IN GENERAL.—The term ‘qualifying 
taxpayer’ means a taxpayer that is not a pro-
hibited foreign entity. 
‘‘(B) PROHIBITED FOREIGN ENTITY.—For 
purposes of this paragraph, the term ‘prohibited 
foreign entity’ means— 
‘‘(i) any foreign entity of concern (as 
defined in section 40207(a)(5) of the In-
frastructure Investment and Jobs Act), 
‘‘(ii) any entity with respect to which 
the government of a covered nation has the 
right or power (directly or indirectly) to 
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appoint or approve the appointment of a 
covered officer, or 
‘‘(iii) any entity 25 percent or more of 
the capital or profits interests of which are 
owned (directly or indirectly) in the aggre-
gate by 1 or more of the following: 
‘‘(I) A covered nation or an enti-
ty described in clause (i) or (ii). 
‘‘(II) A citizen, national, or resi-
dent of a covered nation. 
‘‘(III) An entity organized under 
the laws of a covered nation. 
‘‘(C) COVERED OFFICER.—For purposes of 
this paragraph, the term ‘covered officer’ 
means— 
‘‘(i) any member of the board of direc-
tors, board of supervisors, or an equivalent 
governing body, 
‘‘(ii) the president, senior vice presi-
dent, chief executive officer, chief operating 
officer, chief financial officer, or general 
counsel, or 
‘‘(iii) any individual who performs du-
ties usually associated with a title listed in 
clause (i) or (ii). 
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‘‘(D) COVERED NATION.—For purposes of 
this paragraph, the term ‘covered nation’ has 
the meaning given such term in section 4872(d) 
of title 10, United States Code. 
‘‘(2) QUALIFIED
INVESTMENT.—The qualified 
investment with respect to any critical supply chain 
facility for any taxable year is an amount equal to 
the basis of any qualified property placed in service 
by the taxpayer during such taxable year which is 
part of a such facility. 
‘‘(3) QUALIFYING PROPERTY.— 
‘‘(A) IN GENERAL.—The term ‘qualifying 
property’ means property— 
‘‘(i) that is integral to the operation 
of a critical supply chain facility, 
‘‘(ii) that is tangible property, 
‘‘(iii) with respect to which deprecia-
tion (or amortization in lieu of deprecia-
tion) is allowable, and 
‘‘(iv) which is— 
‘‘(I) constructed, reconstructed, 
or erected by the taxpayer, or 
‘‘(II) acquired by the taxpayer if 
the original use of such property com-
mences with the taxpayer. 
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‘‘(B) RECONSTRUCTED PROPERTY.—Prop-
erty shall be treated as reconstructed for pur-
poses of this paragraph if improvements to such 
property satisfy the substantial improvement 
test of section 1400Z–2(d)(2)(D)(ii). 
‘‘(4) CRITICAL SUPPLY CHAIN FACILITY.—The 
term ‘critical supply chain facility’ means a facil-
ity— 
‘‘(A) the primary purpose of which is the 
manufacturing of— 
‘‘(i) An active pharmaceutical ingre-
dient (as defined in section 2017.1 of title 
21, Code of Federal Regulations (or any 
successor regulations)), 
‘‘(ii) A drug (as defined in section 
201(g) of the Federal Food, Drug, and 
Cosmetic Act), 
‘‘(iii) A biological product (as defined 
in section 351(i)(1) of the Public Health 
Service Act), 
‘‘(iv) A medical countermeasure (as 
defined in section 319F–3(i)(1) of the 
Public Health Service Act), 
‘‘(v) A medical diagnostic device (as 
defined in section 201(h) of the Federal 
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Food, Drug, and Cosmetic Act) intended 
for use in the diagnosis of disease or other 
conditions, 
‘‘(vi) 
Semiconductors 
or 
semicon-
ductor manufacturing equipment, 
‘‘(vii) Aerospace equipment as defined 
under North American Industry Classifica-
tion Code 3364, or 
‘‘(viii) Artificial nanomaterials, and 
‘‘(B) located in— 
‘‘(i) a ‘specified possession’ within the 
meaning of section 937(c), 
‘‘(ii) or Puerto Rico. 
‘‘(5) AGGREGATION RULE.— 
‘‘(A) IN GENERAL.—Members of a quali-
fied affiliated group shall be treated as a single 
taxpayer. 
‘‘(B) QUALIFIED AFFILIATED GROUP.— 
‘‘(i) IN GENERAL.—The term ‘quali-
fied affiliated group’ means an affiliated 
group (as defined in section 1504(a), de-
termined 
without 
regard 
to 
section 
1504(b)(3)) at least 1 member of which 
has made a qualified investment in a crit-
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ical supply chain facility located in an eco-
nomically distressed zone. 
‘‘(ii) 
ECONOMICALLY
DISTRESSED 
ZONE.—For purposes of this subpara-
graph, the term ‘economically distressed 
zone’ means a population census tract 
that— 
‘‘(I) is a qualified opportunity 
zone (as defined in section 1400z– 
1(a)), and 
‘‘(II) has a poverty rate of not 
less than 30 percent. 
‘‘(6) EXEMPTION
FROM
CERTAIN
SPECIAL 
RULES.—The credit determined under subsection (a) 
shall be determined without regard to paragraphs 
(1) and (4) of section 50(b).’’. 
(b) COORDINATION BETWEEN CRITICAL SUPPLY 
CHAINS RESHORING CREDIT AND ELECTRICITY PRODUC-
TION CREDIT.—Section 45(e) of such Code is amended 
by adding at the end the following new subsection: 
‘‘(e) 
COORDINATION
WITH
CRITICAL
SUPPLY 
CHAINS RESHORING INVESTMENT CREDIT.—The term 
‘qualified facility’ shall not include any facility if a credit 
is allowed under section 48F with respect to such facility 
for the taxable year or any prior taxable year.’’. 
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(c) ELECTIVE PAYMENT ALLOWED.— 
(1) IN
GENERAL.—Section 6417(b) of such 
Code is amended by adding at the end the following: 
‘‘(13) The critical supply chains reshoring in-
vestment credit determined under section 48F.’’. 
(2) ELECTION TO BE TREATED AS APPLICABLE 
ENTITY.—Section 6417(d)(1) is amended— 
(A) by redesignating subparagraph (E) as 
subparagraph (F), and 
(B) by inserting after subparagraph (D) 
the following new subparagraph: 
‘‘(E) ELECTION WITH RESPECT TO CRIT-
ICAL SUPPLY CHAINS RESHORING CREDIT.—If a 
taxpayer other than an entity described in sub-
paragraph (A) makes an election under this 
subparagraph with respect to any taxable year 
in which such taxpayer has placed in service a 
critical supply chain facility (as defined in sec-
tion 48F(b)(4)), such taxpayer shall be treated 
as an applicable entity for purposes of this sec-
tion for such taxable year, but only with respect 
to the credit described in subsection (b)(13).’’. 
(d) 
CREDIT
MADE
TRANSFERABLE.—Section 
6418(f)(1)(A) of such Code is amended by adding at the 
end the following: 
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‘‘(xii) The critical supply chains re-
shoring 
investment 
credit 
determined 
under section 48F.’’. 
(e) CREDIT INCLUDED IN INVESTMENT CREDIT.— 
Section 46 of such Code is amended by striking ‘‘and’’ 
at the end of paragraph (6), by striking the period at the 
end of paragraph (7) and inserting ‘‘, and’’, and by adding 
at the end the following new paragraph: 
‘‘(8) the critical supply chains reshoring invest-
ment credit.’’. 
(f) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service after 
December 31, 2024. 
SEC. 3. INCREASE IN DEEMED CREDIT FOR TAXES PAID TO 
POSSESSION OF THE UNITED STATES. 
(a) IN GENERAL.—Section 960(d) of the Internal 
Revenue Code of 1986 is amended by adding at the end 
the following new paragraph: 
‘‘(4) INCREASE FOR TAXES PAID TO POSSES-
SION OF UNITED STATES.—In the case of tested for-
eign income taxes paid or accrued to a possession of 
the United States, paragraph (1) shall be applied by 
substituting ‘100 percent’ for ‘80 percent’.’’. 
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(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxes paid or accrued after De-
cember 31, 2024. 
Æ 
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