This bill would add a new federal tax credit for translational research on neurodegenerative diseases and psychiatric conditions. The credit equals 25% of amounts paid or incurred in a taxable year that are necessary for such translational research. The bill sets annual national limits on the total credit available: $1,000,000,000 for 2026, $2,000,000,000 for each year 2027–2030, and $1,000,000,000 for 2031. The Secretary of the Treasury must allocate the available credit amounts among applicants, and must issue regulations in consultation with HHS, the FDA, and the NIH. The regulations must set an application process and require allocation based on scientific merit, include all phases of research, emphasize new therapeutics and devices for central nervous system disorders, set standards for repurposing drugs and devices, and set standards for public-private partnerships with priority for collaboration and sharing intellectual property held by tax-exempt entities.
The bill allows certain tax-exempt entities (federal, state, tribal, or local government entities and 501(c)(3) organizations) to elect to transfer all or part of their credit to an "eligible project partner" identified in the allocation application. The partner that receives the transfer is treated as the taxpayer for that portion of the credit. The bill also includes special rules for partnerships and timing rules for when a partner may take the credit.
The bill says expenses counted under this new credit generally cannot also be counted for the existing credit for increasing research expenditures (section 41) for the same taxable year, though those expenses may be used to determine base period research expenses for future section 41 calculations. It adds a rule that disallows deductions equal to the amount of this credit for the same expenses. The credit is added to the general business credit rules. The credit would not be allowed for taxable years beginning after December 31, 2035. The amendments take effect on the date of enactment.
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