S. 1613 — Tax Relief for New Businesses Act

This section consolidates the treatment of organizational expenditures (previously deductible under separate IRC §248 for corporations) with start-up expenditures under IRC §195 for all businesses, defines organizational expenditures as those incident to creating a corporation or partnership that are capitalizable and amortizable if the entity has a limited life, and repeals §248 along with related cross-references. It increases the dollar limitation for immediate deduction of the aggregate amount to $50,000 (from $5,000), with the phase-out threshold raised to $150,000 (from $50,000), and requires partnerships and S corporations to make the amortization election at the entity level. The section further adds special net operating loss (NOL) rules under new IRC §172(g), allowing an irrevocable election to apply NOL rules separately to start-up and organizational NOLs (i.e., NOLs attributable solely to the §195 deduction)—with 100% offset against taxable income (instead of 80%), exemption from business interest limits, and adjustment to other NOLs for the §195 deduction amount. The changes apply to expenses paid or incurred in taxable years beginning after December 31, 2025.