I 
117TH CONGRESS 
1ST SESSION 
H. R. 590 
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 
JANUARY 28, 2021 
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 manufac-
turing equipment from China to the United States, and 
for other purposes. 
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 ‘‘Reshoring American 
Manufacturing Act of 2021’’ or as the ‘‘RAM Act of 
2021’’. 
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SEC. 2. CREDIT FOR CERTAIN EXPENSES OF MOVING MAN-
UFACTURING EQUIPMENT FROM CHINA TO 
THE UNITED STATES. 
(a) IN GENERAL.—Subpart D of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
section: 
‘‘SEC. 45U. MANUFACTURING RESHORING CREDIT. 
‘‘(a) IN GENERAL.—For purposes of section 38, the 
manufacturing reshoring credit for any taxable year is the 
applicable percentage of the eligible reshoring expenses 
paid or incurred by the taxpayer during such taxable year. 
‘‘(b) LIMITATION.—The credit determined under sub-
section (a) with respect to any taxpayer for any taxable 
year shall not exceed $25,000,000. 
‘‘(c) APPLICABLE PERCENTAGE.—For purposes of 
this section, the term ‘applicable percentage’ means— 
‘‘(1) in the case of any taxable year beginning 
in 2021 or 2022, 100 percent, 
‘‘(2) in the case of any taxable year beginning 
in 2023, 80 percent, and 
‘‘(3) in the case of any taxable year beginning 
in 2024, 60 percent. 
‘‘(d) ELIGIBLE RESHORING EXPENSES.—For pur-
poses of this section— 
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‘‘(1) IN GENERAL.—The term ‘eligible reshoring 
expenses’ means, with respect to any taxpayer, 
amounts paid or incurred by such taxpayer for the 
transportation (including any import duties, fees, or 
tariffs imposed with respect to such transportation) 
of qualified manufacturing equipment from China to 
the United States. 
‘‘(2) 
QUALIFIED
MANUFACTURING
EQUIP-
MENT.—The term ‘qualified manufacturing equip-
ment’ means, with respect to any taxpayer, manu-
facturing equipment owned by such taxpayer 
which— 
‘‘(A) before the transportation referred to 
in paragraph (1) was used by such taxpayer to 
manufacture tangible property in China, and 
‘‘(B) after the transportation referred to in 
paragraph (1) is used by such taxpayer to man-
ufacture tangible property in the United States. 
‘‘(e) RECAPTURE.—If any qualified manufacturing 
equipment with respect to which a credit was allowed 
under this section is transported outside the United States 
(after transportation to the United States as described in 
subsection (d)) during the 3-year period beginning on the 
date (after such transportation) on which such property 
is placed in service by the taxpayer in the United States, 
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the tax imposed under this chapter on such taxpayer for 
the taxable year which includes the date on which such 
property is so transported outside the United States shall 
be increased by the amount of the credit determined under 
this section with respect to such property. 
‘‘(f) SPECIAL RULES.— 
‘‘(1) DENIAL OF DOUBLE BENEFIT.—Any de-
duction or credit allowed under this title (other than 
this section) with respect to any eligible reshoring 
expenses shall be reduced by the amount of the cred-
it determined under this section. 
‘‘(2) AGGREGATION
RULE.—For purposes of 
the dollar limitation imposed under subsection (b), 
all members of the same controlled group of corpora-
tions (within the meaning of section 267(f)) and all 
persons under common control (within the meaning 
of section 52(b) but determined by treating an inter-
est of more than 50 percent as a controlling inter-
est) shall be treated as 1 person and such dollar lim-
itation shall be allocated in such manner as the Sec-
retary may provide. 
‘‘(3) 
ELECTION
TO
NOT
HAVE
SECTION 
APPLY.—No credit shall be determined under sub-
section (a) with respect to any taxpayer for any tax-
able year if such taxpayer make an election under 
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this paragraph (at such time and in such manner as 
the Secretary may provide) to have such subsection 
not apply for such taxable year. 
‘‘(g) TERMINATION.—No credit shall be determined 
under this section for any taxable year beginning after De-
cember 31, 2024.’’. 
(b) CREDIT ALLOWED AS PART OF GENERAL BUSI-
NESS CREDIT.—Section 38(b) of such Code is amended 
by striking ‘‘plus’’ at the end of paragraph (32), by strik-
ing the period at the end of paragraph (33) and inserting 
‘‘, plus’’, and by adding at the end the following new para-
graph: 
‘‘(34) the manufacturing reshoring credit deter-
mined under section 45U(a).’’. 
(c) CLERICAL AMENDMENT.—The table of sections 
for subpart D of part IV of subchapter A of chapter 1 
of such Code is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 45U. Manufacturing reshoring credit.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to amounts paid or incurred after 
the date of the enactment of this Act, in taxable years 
ending after such date. 
Æ 
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