RAM Act of 2021
Bill: H.R.590 | Sponsor: Rep. Posey, Bill (R-FL)
Policy area: Taxation

Summary:
Reshoring American Manufacturing Act of 2021 or the RAM Act of 2021
This bill allows business taxpayers a tax credit, up to $25 million in a taxable year, for the cost of eligible reshoring expenses. The bill defines eligible reshoring expenses as amounts paid for the transportation (including any import duties, fees, or tariffs imposed with respect to such transportation) of manufacturing equipment from China to the United States. The credit expires after 2024.

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.

    Be it enacted by the Senate and House of Representatives 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''.

SEC. 2. CREDIT FOR CERTAIN EXPENSES OF MOVING MANUFACTURING EQUIPMENT 
              FROM CHINA TO THE UNITED STATES.

    (a) In General.--Subpart D of part IV of subchapter 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 subsection (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 purposes of this section--
            ``(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 equipment.--The term 
        `qualified manufacturing equipment' means, with respect to any 
        taxpayer, manufacturing 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 manufacture 
                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, 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 deduction 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 credit 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 corporations (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 
        interest of more than 50 percent as a controlling interest) 
        shall be treated as 1 person and such dollar limitation shall 
        be allocated in such manner as the Secretary may provide.
            ``(3) Election to not have section apply.--No credit shall 
        be determined under subsection (a) with respect to any taxpayer 
        for any taxable year if such taxpayer make an election under 
        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 December 31, 2024.''.
    (b) Credit Allowed as Part of General Business Credit.--Section 
38(b) of such Code is amended by striking ``plus'' at the end of 
paragraph (32), by striking the period at the end of paragraph (33) and 
inserting ``, plus'', and by adding at the end the following new 
paragraph:
            ``(34) the manufacturing reshoring credit determined 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 following 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.
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