research small business pass-thru entity (as defined in section 469(c)(4)), . (d) Exception to limitation on pass-Thru of research credit Subsection (g) of section 41 of such Code is amended by adding at the end the following: Paragraphs (2) and (4) shall not apply with respect to any specified medical research small business pass-thru entity (as defined in section 469(c)(4)). . (e) Effective date The amendments made by this section shall apply to losses and credits arising in taxable years beginning after December 31, 2020. IV Growth in Innovation and Technology Breakthroughs 401. Simplification and expansion of deduction for start-up and organizational expenditures (a) In general Section 195 of the Internal Revenue Code of 1986 is amended by redesignating subsections (c) and (d) as subsections (d) and (e), respectively, and by striking all that precedes subsection (d) (as so redesignated) and inserting the following: 195. Start-up and organizational expenditures (a) Capitalization of expenditures Except as otherwise provided in this section, no deduction shall be allowed for start-up or organizational expenditures. (b) Election To deduct (1) In general If a taxpayer elects the application of this subsection with respect to any active trade or business— (A) the taxpayer shall be allowed a deduction for the taxable year in which such active trade or business begins in an amount equal to the lesser of— (i) the aggregate amount of start-up and organizational expenditures paid or incurred in connection with such active trade or business, or (ii) $20,000, reduced (but not below zero) by the amount by which such aggregate amount exceeds $120,000, and (B) the remainder of such start-up and organizational expenditures shall be charged to capital account and allowed as an amortization deduction determined by amortizing such expenditures ratably over the 180-month period beginning with the month in which the active trade or business begins. (2) Application to organizational expenditures In the case of organizational