Sec. 3. Expensing of costs directly connected with moving manufacturing from China to the United States

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Part VI of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 179E the following new section: A specified taxpayer may elect to treat amounts paid or incurred for repatriation property as an expense which is not chargeable to capital account. Any cost so treated shall be allowed as a deduction for the taxable year in which such repatriation property is placed in service. For purposes of this section, the term specified taxpayer means any taxpayer engaged in the trade or business of manufacturing any product if— as of the date of the enactment of this section, such taxpayer manufactured such product in China, and as of the date which is 3 years after the date that the repatriation property is placed in service— such taxpayer does not manufacture such product in China, and the quantity of such product manufactured in the United States by such taxpayer has increased (relative to such quantity determined as of the date of the enactment of this section) by an amount not less than the quantity of such product manufactured in China as of the date of the enactment of this section.

For purposes of this section, the term repatriation property means any property (including any real property) if— such property is used by the taxpayer in the United States to manufacture the product referred to in subsection (b), the acquisition of such property by the taxpayer is directly connected to replacing the productive capacity lost by the taxpayer by reason of ceasing manufacturing of such product in China (as described in subsection (b)(2)(A)), and such property is of a character which is subject to the allowance for depreciation provided in section 167.

Rules similar to the rules of subsection (c), and paragraphs

(4)and

(10)of subsection (d), of section 179 shall apply for purposes of this section. . The table of sections for part VI of subchapter B of chapter 1 of such Code is amended by inserting after the item relating to section 179E the following new item: Sec. 179F. Election to expense certain assets directly connected to moving manufacturing from China to the United States. . The amendments made by this section shall apply to property placed in service after the date of the enactment of this Act, in taxable years ending after such date.