Tax Relief for New Businesses Act of 2025
The Tax Relief for New Businesses Act of 2025 was introduced in the Senate on May 6, 2025.
SECTION 1. SHORT TITLE
This Act may be cited as the ‘Tax Relief for New Businesses Act’.
SEC. 2. NEW BUSINESS EXPENDITURES
(a) CONSOLIDATION OF DEDUCTION FOR START-UP AND ORGANIZATIONAL EXPENDITURES — (1) IN GENERAL — Section 195(a) of the Internal Revenue Code of 1986 is amended by inserting ‘or organizational’ after ‘start-up’.
- (2) ORGANIZATIONAL EXPENDITURES — Subsection (c) of section 195 of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph:
- ‘(3) ORGANIZATIONAL EXPENDITURES. — The term ‘organizational expenditures’ means any expenditure which—
- ‘(A) is incident to the creation of a corporation or a partnership,
- ‘(B) is chargeable to capital account, and
- ‘(C) is of a character which, if expended incident to the creation of a corporation or a partnership having a limited life, would be amortizable over such life.”
CONSOLIDATION OF DEDUCTION FOR START-UP AND ORGANIZATIONAL EXPENDITURES — (1) IN GENERAL —
(i) Section 195(b)(1) is amended— (A) by striking ‘with respect to any start-up expenses’ and inserting ‘with respect to any active trade or business’, (ii) by striking ‘the amount of start-up expenditures with respect to’ in subsection (A)(i) thereof and inserting ‘the aggregate amount of start-up and organizational expenditures paid in connection with’, and
‘In the case of a partnership or S corporation, the election under the preceding sentence shall be made at the entity level.’
SECTION 709. 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 (or to sell) an interest in the partnership.
The item relating to section 709 in the table of sections for part I of subchapter K of chapter 1 of such Code is amended to read as follows:
Sec. 709. Treatment of syndication fees.
EFFECTIVE DATE
The amendments made by this section shall apply to expenses paid or incurred in taxable years beginning after December 31, 2025.