Makes three major changes to the tax code: it permanently restores 100% bonus depreciation for qualifying property (and removes a prior planting cutoff for certain plants), it raises annual depreciation deductions for residential rental and nonresidential real property by applying a new “neutral cost recovery ratio” tied to the GDP deflator plus a 3% factor (with a one‑time irrevocable opt‑out), and it rewrites rules for research and experimental (R&E) spending so qualifying R&E costs can be deducted currently (with an alternative amortization election and eligibility limits). The bill applies some changes retroactively (treated as if included in the 2017 law) and sets specific effective dates for the R&E and real‑property rules, so taxpayers, accountants, and state tax systems will need to consider amended or future returns and compliance implications.
Amends paragraph (6) of section 168(k) of the Internal Revenue Code to define the "applicable percentage" as 100 percent for property placed in service (or, for a specified plant described in paragraph (5), a plant which is planted or grafted) after September 27, 2017.
Makes multiple conforming textual amendments to paragraph (2) of section 168(k), including edits in subparagraph (A) (changes to clauses (i)(V), (ii), and removal of clause (iii)), subparagraph (B) (edits and redesignation of clauses), subparagraph (C) (striking specified text and updating cross-references), and subparagraph (E) (striking clause (i) and redesignating clauses (ii) and (iii) as (i) and (ii)). The provision lists each strike/insert/redesignation action but does not reproduce inserted text.
In paragraph (5)(A) of section 168(k), strikes the phrase "planted before January 1, 2027, or is grafted before such date to a plant that has already been planted," and inserts the phrase "planted or grafted." This removes the January 1, 2027 planting/grafting cutoff language.
Amends section 460(c)(6)(B) of the Internal Revenue Code by striking the existing trailing clause and inserting: "which has a recovery period of 7 years or less."
Effective date provision: The amendments made by this section shall take effect as if included in section 13201 of Public Law 115–97. (No explicit calendar date is provided in this section text.)
Who is affected and how:
Businesses that buy equipment and other qualified property: These businesses get immediate, full expensing (100% bonus depreciation) for qualifying assets placed in service after Sept. 27, 2017, lowering current taxable income and encouraging capital investment. The permanent rule simplifies planning for capital purchases but may require retroactive tax adjustments.
Residential rental owners and nonresidential real property owners (landlords, commercial property owners): The new neutral cost recovery ratio raises annual tax deductions for building and related property. Owners can choose a one‑time opt‑out, but most will see reduced taxable income in years the ratio applies. The extra deduction does not change tax basis and is treated specially for recapture rules.
Companies performing R&E (manufacturers, technology firms, biotech, startups): Restoring or allowing current deductibility for qualifying R&E spending (with an alternative amortization option) improves near‑term cash flow and can especially help small/young firms that previously had to capitalize/amortize these costs. Eligibility limits and exclusions mean not all outlays qualify.
Taxpayers generally and tax practitioners: The mix of retroactive treatment, new elections, and computation rules increases compliance work. Some taxpayers may need to amend past returns (e.g., returns covering 2022 onward for R&E), and preparers will need to manage irrevocable elections and new reporting.
Federal and state budgets: The near‑term federal revenue effect is likely negative because deductions are accelerated; states that conform to federal tax changes will see related impacts unless they decouple. Long‑term revenue effects depend on whether the changes materially increase investment and taxable income later.
Administrative agencies: IRS and state tax departments will need to issue guidance, forms, and rules for calculating the neutral cost recovery ratio, handling elections, and processing any amended filings.
Overall effect: The bill mostly benefits capital‑intensive businesses, landlords, and R&E performers by accelerating deductions, while increasing tax complexity and producing short‑term revenue loss for the federal government. The retroactive and varying effective dates raise additional compliance and planning issues.
Last progress June 12, 2025 (8 months ago)
Introduced on June 12, 2025 by Glenn Grothman
Referred to the House Committee on Ways and Means.
ALIGN Act
Updated 2 days ago
Last progress January 22, 2025 (1 year ago)
CREATE JOBS Act
ALIGN Act
Updated 2 days ago
Last progress June 12, 2025 (8 months ago)
Updated 1 week ago
Last progress January 21, 2025 (1 year ago)
Updated 12 hours ago
Last progress March 10, 2025 (11 months ago)