This legislation proposes significant amendments to the Internal Revenue Code of 1986, primarily aimed at assisting new businesses with their initial expenses. The bill consolidates the tax treatment of start-up and organizational expenditures into a single provision under Section 195, streamlining the rules for deducting these costs. It also defines "organizational expenditures" to include costs incident to the creation of a corporation or partnership that are chargeable to a capital account. A key provision of this bill is the substantial increase in the immediate deduction limit for these combined expenditures, raising it from $5,000 to $50,000 . Concurrently, the threshold at which this immediate deduction begins to phase out is increased from $50,000 to $150,000 , allowing more businesses to benefit from the full deduction. The bill also makes numerous conforming amendments, including the repeal of separate sections for corporate and partnership organizational expenditures (Sections 248 and 709, respectively) and integrating their provisions into Section 195. Furthermore, the legislation introduces special rules for the application of net operating losses (NOLs) related to start-up and organizational expenditures. Taxpayers can elect to treat these specific NOLs separately, allowing them to offset 100 percent of taxable income, rather than the standard 80 percent limitation. This election also removes certain carryforward limitations for these particular NOLs, providing greater flexibility for new businesses, with these changes taking effect for expenses paid or incurred in taxable years beginning after December 31, 2025.