HouseH.R. 10657119th Congress

SPROUT Act of 2026

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[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 10657 Introduced in House (IH)]

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119th CONGRESS
  2d Session
                               H. R. 10657

     To amend the Internal Revenue Code of 1986 to allow a special 
depreciation allowance for qualified early childhood education centers.

_______________________________________________________________________

                    IN THE HOUSE OF REPRESENTATIVES

                            October 1, 2026

  Mr. Crank introduced the following bill; which was referred to the 
                      Committee on Ways and Means

_______________________________________________________________________

                                 A BILL

 
     To amend the Internal Revenue Code of 1986 to allow a special 
depreciation allowance for qualified early childhood education centers.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Supporting Early Childhood Education 
Opportunities through Upfront Tax Deductions Act of 2026'' or the 
``SPROUT Act of 2026''.

SEC. 2. SPECIAL DEPRECIATION ALLOWANCE FOR QUALIFIED EARLY CHILDHOOD 
              EDUCATION CENTERS.

    (a) In General.--Section 168 of the Internal Revenue Code of 1986 
is amended by adding at the end the following new subsection:
    ``(o) Special Allowance for Qualified Early Childhood Education 
Centers.--
            ``(1) In general.--In the case of any qualified early 
        childhood education center of a taxpayer making an election 
        under this section--
                    ``(A) the depreciation deduction provided by 
                section 167(a) for the taxable year in which such 
                property is placed in service shall include an 
                allowance equal to 100 percent of the adjusted basis of 
                the qualified early childhood education center, and
                    ``(B) the adjusted basis of the qualified early 
                childhood education center shall be reduced by the 
                amount of such deduction before computing the amount 
                otherwise allowable as a depreciation deduction under 
                this chapter for such taxable year and any subsequent 
                taxable year.
            ``(2) Qualified early childhood education center.--For 
        purposes of this subsection, the term `qualified early 
        childhood education center' means that portion of any 
        nonresidential real property--
                    ``(A) to which this section applies,
                    ``(B) which is used by the taxpayer as part of an 
                early childhood education center which is licensed by 
                any State to provide care for children under the age of 
                5,
                    ``(C) in the case of a taxpayer that is not 
                licensed to provide such care, with respect to which 
                such taxpayer is party to a written binding contract 
                with a person licensed by any State to provide care at 
                such early childhood education center before 
                construction of such property begins,
                    ``(D) which is placed in service in the United 
                States or any possession thereof,
                    ``(E) which is designated by the taxpayer in the 
                election made under this section,
                    ``(F) the original use of which commences with the 
                taxpayer, and
                    ``(G) which is placed in service before December 
                31, 2031.
            ``(3) Exclusion of office space, etc.--The term `qualified 
        early education center' shall not include any nonresidential 
        real property which is not a part of a building in which child 
        care is provided.
            ``(4) Extension of placed in service date under certain 
        circumstances.--The Secretary may extend the date under 
        paragraph (2)(G) with respect to any property that meets the 
        requirements of subparagraphs (A) through (F) of paragraph (1) 
        if the Secretary determines that an act of God (as defined in 
        section 101(1) of the Comprehensive Environmental Response, 
        Compensation, and Liability Act of 1980) prevents the taxpayer 
        from placing such property in service before such date.
            ``(5) Special rules.--Rules similar to the rules of 
        paragraphs (3), (4), (5), and (6) of subsection (n) shall apply 
        to this subsection.
            ``(6) Regulations.--The Secretary shall issue such 
        regulations or other guidance as may be necessary or 
        appropriate to carry out the purposes of this subsection, 
        including regulations or other guidance.''.
    (b) Treatment of Qualified Early Childhood Education Center as 
Section 1245 Property.--Section 1245(a)(3) is amended--
            (1) in subparagraph (F), by striking ``or'',
            (2) in subparagraph (G), by striking the period and 
        inserting ``, or'', and
            (3) by adding at the end the following new subparagraph:
                    ``(H) any qualified early childhood education 
                center (as defined in section 168(o)(2))''.
    (c) Effective Date.--The amendments made by this section shall 
apply to property placed in service after the date of the enactment of 
this Act.
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