,,ii #aafth ,,congress #ast ,session ,s4 #bhda ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,november #ac1 #bjai,ms4 ,baldwin 7for herself and ,mr4 ,hoeven7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to increase the limitations for deductible new business expenditures and to consolidate provisions for start-up and organizational expenditures4 #a4 ,short title ,this ,act may be cited as the ,support ,our ,start-,ups ,act4 #b4 ,new business expenditures 7a7 ,in general ,subsections 7a7 and 7b7 of section #aie of the ,internal ,revenue ,code of #aihf are both amended by inserting and organizational after start-up each place it appears4 7b7 ,organizational expenditures ,subsection 7c7 of section #aie of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new paragraph3 7#c7 ,organizational expenditures ,the term organizational expenditures means any expenditure which-- 7,a7 is incident to the creation of a corporation1 ,s corporation1 or partnership1 7,b7 is chargeable to capital account1 and 7,c7 is of a character which1 if expended incident to the creation of a corporation1 ,s corporation1 or partnership having a limited life1 would be amortizable over such life4 4 7c7 ,dollar amounts 7#a7 ,in general ,clause 7ii7 of section #aie7;b77#a77;,a7 of the ,internal ,revenue ,code of #aihf is amended-- 7,a7 by striking #e1jjj and inserting #bj1jjj2 and 7,b7 by striking #ej1jjj and inserting #abj1jjj4 7#b7 ,adjustment for inflation ,subsection 7b7 of section #aie of such ,code is amended by adding at the end the following new paragraph3 7#d7 ,adjustment for inflation ,in the case of a taxable year beginning after ,december #ca1 #bjbj1 the #bj1jjj and #abj1jjj amounts in paragraph 7#a77;,a77ii7 shall each be increased by an amount equal to-- 7,a7 such amount1 multiplied by 7,b7 the cost-of-living adjustment determined under section #a7;f77#c7 for the calendar year in which the taxable year begins1 determined by substituting calendar year #bjai for calendar year #bjaf in subparagraph 7,a77ii7 thereof4 ,if any increase determined under the preceding sentence is not a multiple of #a1jjj1 such amount shall be rounded to the nearest multiple of #a1jjj4 4 7d7 ,amortization treatment ,subparagraph 7,b7 of section #aie7;b77#a7 of the ,internal ,revenue ,code of #aihf1 as amended by subsection 7a71 is amended to read as follows3 7,b7 the remainder of such start-up and organizational expenditures shall be charged to capital account and allowed as an amortization deduction determined by amortizing such expenditures ratably over the #ae-year period beginning with the midpoint of the taxable year in which the active trade or business begins4 4 7e7 ,application to disregarded entities ,subsection 7c7 of section #aie of the ,internal ,revenue ,code of #aihf1 as amended by subsection 7b71 is amended by adding at the end the following new paragraph3 7#d7 ,application to disregarded entities ,in the case of any entity with a single owner which is disregarded as an entity separate from its owner1 this section shall be applied in the same manner as if such entity were a corporation4 4 7f7 ,allowance of deduction upon liquidation or disposition ,section #aie of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7e7 ,allowance of deduction upon liquidation or disposition 7#a7 ,liquidation of a business entity ,in the case of a complete liquidation by the taxpayer of any corporation1 ,s corporation1 or partnership1 any start-up and organizational expenditures paid or incurred in connection with such partnership1 ,s corporation1 or corporation which were not allowed as a deduction by reason of this section shall be allowed as a loss to the extent provided under section #afe4 7#b7 ,disposition of trade or business ,in the case of a complete disposition by the taxpayer of any trade or business1 any start-up and organizational expenditures paid or incurred in connection with such trade or business which were not allowed as a deduction by reason of this section 7and which are not taken into account under paragraph 7#a77 shall be allowed as a loss to the extent provided under section #afe4 4 7g7 ,conforming amendments 7#a7 ,section #aie7;b77#a7 of the ,internal ,revenue ,code of #aihf is amended-- 7,a7 by inserting 7or1 in the case of a partnership or ,s corporation1 the entity elects7 after ,if a taxpayer elects1 7,b7 by inserting 7or the entity1 as the case may be7 after the taxpayer in subparagraph 7,a71 and 7,c7 by adding at the end the following flush sentence3 ,in the case of a partnership or ,s corporation1 the election under the preceding sentence shall be made at the entity level4 4 7#b7 ,section #aie7;b77#b7 of such ,code is amended-- 7,a7 by striking amortization period4--,in any case and inserting the following3 amortization period4-- 7,a7 ,in general ,in any case 2 and 7,b7 by adding at the end the following new subparagraph3 7,b7 ,special rule ,in the case of a partnership or ,s corporation1 subparagraph 7,a7 shall be applied at the entity level4 4 7#c7 ,section #aie7;b7 of such ,code is amended by striking paragraph 7#c74 7#d7 7,a7 ,part ,,viii of subchapter ,b of chapter #a of such ,code is amended by striking section #bdh 7and by striking the item relating to such section in the table of sections for such part74 7,b7 ,section #ef7;g77#d77;,d77ii7 of such ,code is amended by striking ,sections #agc and #bdh and inserting ,section #agc4 7,c7 ,section #agj7;b77#b77;,c77ii7 of such ,code is amended by striking 7except section #bdh74 7,d7 ,section #cab7n77#c7 of such ,code is amended by striking ,sections #agc and #bdh and inserting ,section #agc4 7,e7 ,section #ece7;b77#c7 of such ,code is amended by striking 7except section #bdh74 7,f7 ,section #ede7;b77#c7 of such ,code is amended by striking 7except section #bdh74 7,g7 ,section #hcd7;c77#g7 of such ,code is amended by striking 7except section #bdh74 7,h7 ,section #heb7;b77#b77;,c7 of such ,code is amended by striking 7except section #bdh74 7,i7 ,section #heg7;b77#b77;,a7 of such ,code is amended by striking 7except section #bdh74 7,j7 ,section #acfc7;b7 of such ,code is amended by inserting and at the end of paragraph 7#b71 by striking paragraph 7#c71 and by redesignating paragraph 7#d7 as paragraph 7#c74 7,k7 ,section #acge7;b77#a77;,b77i7 of such ,code is amended by striking 7other than the deduction allowed by section #bdh1 relating to organization expenditures74 7#e7 ,part ,i of subchapter ,k of chapter #a of such ,code is amended by striking section #gji 7and by striking the item relating to such section in the table of sections for such part74 7#f7 ,the heading of section #aie of such ,code 7and the item relating to such section in the table of sections for part ,,vi of subchapter ,b of chapter #a of such ,code7 are each amended by inserting and organizational after ,start-up4 7h7 ,effective date ,the amendments made by this section shall apply to expenses paid or incurred in taxable years beginning after ,december #ca1 #bjai4