,,ii #aaith ,,congress #ast ,session ,s4 #afac ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,may #f1 #bjbe ,ms4 ,rosen 7for herself1 ,mrs4 ,shaheen1 ,ms4 ,baldwin1 ,mr4 ,wyden1 ,mr4 ,blumenthal1 ,ms4 ,klobuchar1 ,mr4 ,heinrich1 ,mr4 ,coons1 ,ms4 ,slotkin1 ,mr4 ,gallego1 and ,ms4 ,alsobrooks7 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 expenditures1 to consolidate provisions for start-up and organizational expenditures1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,tax ,relief for ,new ,businesses ,act4 #b4 ,new business expenditures 7a7 ,consolidation of deduction for start-,up and organizational expenditures 7#a7 ,in general ,section #aie7;a7 of the ,internal ,revenue ,code of #aihf is amended by inserting or organizational after start-up4 7#b7 ,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 corporation or a partnership1 7,b7 is chargeable to capital account1 and 7,c7 is of a character which1 if expended incident to the creation of a corporation or a partnership having a limited life1 would be amortizable over such life4 4 7#c7 ,conforming amendments 7,a7 ,section #aie7;b77#a7 is amended-- 7i7 by striking with respect to any start-up expenses and inserting with respect to any active trade or business1 7ii7 by striking the amount of start-up expenditures with respect to in subparagraph 7,a77i7 thereof and inserting the aggregate amount of start-up and organizational expenditures paid in connection with1 and 7iii7 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-- 7i7 by striking amortization period4--,in any case and inserting the following3 amortization period4-- 7,a7 ,in general ,in any case 1 and 7ii7 by adding at the end the following new subparagraph3 7,b7 ,special partnership 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 7i7 ,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 7ii7 ,section #agj7;b77#b77;,c77ii7 of such ,code is amended by striking 7except section #bdh74 7iii7 ,section #cab7n77#c7 of such ,code is amended by striking ,sections #agc and #bdh and inserting ,section #agc4 7iv7 ,section #ece7;b77#c7 of such ,code is amended by striking 7except section #bdh74 7v7 ,paragraphs 7#c7 and 7#d7 of section #ede7;b7 of such ,code are each amended by striking 7except section #bdh74 7vi7 ,section #hcd7;c77#g7 of such ,code is amended by striking 7except section #bdh74 7vii7 ,section #heb7;b77#b77;,c7 of such ,code is amended by striking 7except section #bdh74 7viii7 ,section #heg7;b77#b77;,a7 of such ,code is amended by striking 7except section #bdh74 7ix7 ,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 7x7 ,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 7i7 ,section #gji of such ,code is amended to read as follows3 #gji4 ,treatment of syndication fees ,no deduction shall be allowed under this chapter to a partnership or to any partner of the partnership for any amounts paid or incurred to promote the sale of 7or to sell7 an interest in the partnership4 4 7ii7 ,the item relating to section #gji in the table of sections for part ,i of subchapter ,k of chapter #a of such ,code is amended to read as follows3 ,sec4 #gji4 ,treatment of syndication fees4 4 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 7b7 ,increase in limitation ,clause 7ii7 of section #aie7;b77#a77;,a7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking #e1jjj and inserting #ej1jjj1 and 7#b7 by striking #ej1jjj and inserting #aej1jjj4 7c7 ,application of net operating loss rules ,section #agb of the ,internal ,revenue ,code of #aihf is amended by redesignating subsection 7g7 as subsection 7h7 and by inserting after subsection 7f7 the following new subsection3 7g7 ,special rules for start-,up and organizational expenditures 7#a7 ,in general ,in the case of a taxpayer making an election under this subsection-- 7,a7 this section shall be applied separately to start-up and organizational net operating losses and other net operating losses1 7,b7 in applying this section to start-up and organizational net operating losses-- 7i7 subsection 7a77#b77;,b7 shall be applied by substituting #ajj percent for #hj percent in clause 7i7 thereof1 and 7ii7 subsection 7b77#b77;,c7 shall not apply1 and 7,c7 in applying this section to other net operating losses1 for purposes of subsections 7a77#b77;,b77ii77,i7 and 7b77#b71 taxable income shall be reduced by the amount of the deduction allowed under this section with respect to start-up and organizational net operating losses4 7#b7 ,start-up and organizational net operating loss ,for purposes of this section1 the term start-up and organizational net operating loss means the amount which would be a net operating loss if the only deduction taken into account were the deduction allowed under section #aie4 7#c7 ,other net operating losses ,for purposes of this section1 the term other net operating loss means the net operating loss determined without regard to the deduction allowed under section #aie4 7#d7 ,election ,an election under this section shall be made at such time and in such form and manner as the ,secretary shall prescribe4 ,such an election1 once made1 shall be irrevocable4 4 7d7 ,effective date ,the amendments made by this section shall apply to expenses paid or incurred in taxable years beginning after ,december #ca1 #bjbe4