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.

(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.