chapter 1 of such Code is amended to read as follows: Sec. 195. Start-up and organizational expenditures. . (e) Effective date The amendments made by this section shall apply to expenditures paid or incurred in connection with active trades or businesses which begin in taxable years beginning after December 31, 2019. 402. Preservation of start-up net operating losses and tax credits after ownership change (a) Application to net operating losses Section 382(d) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (4) Exception for start-up losses (A) In general In the case of any net operating loss carryforward described in paragraph (1)(A) which arose in a start-up period taxable year, the amount of such net operating loss carryforward otherwise taken into account under such paragraph shall be reduced by the net start-up loss determined with respect to the trade or business referred to in subparagraph (B)(i) for such start-up period taxable year. (B) Start-up period taxable year The term start-up period taxable year means any taxable year of the old loss corporation which— (i) begins before the close of the 3-year period beginning on the date on which any trade or business of such corporation begins as an active trade or business (as determined under section 195(d)(2) without regard to subparagraph (B) thereof), and (ii) ends after May 31, 2020. (C) Net start-up loss (i) In general The term net start-up loss means, with respect to any trade or business referred to in subparagraph (B)(i) for any start-up period taxable year, the amount which bears the same ratio (but not greater than 1) to the net operating loss carryforward which arose in such start-up period taxable year as— (I) the net operating loss (if any) which would have been determined for such start-up period taxable year if only items of income, gain, deduction, and loss properly allocable to such trade or business were taken into account, bears to (II) the amount of the net operating loss determined for such