I
119THCONGRESS
1
STSESSION H. R. 2941
To amend the Internal Revenue Code of 1986 to improve the historic
rehabilitation tax credit, and for other purposes.
IN THE HOUSE OF REPRESENTATIVES
APRIL17, 2025
Mr. L
AHOOD(for himself and Mr. SUOZZI) 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 improve
the historic rehabilitation tax credit, and for other purposes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Historic Tax Credit 4
Growth and Opportunity Act of 2025’’. 5
SEC. 2. FULL CREDIT ALLOWED IN THE YEAR BUILDING 6
PLACED IN SERVICE. 7
(a) I
NGENERAL.—Section 47(a) of the Internal Rev-8
enue Code of 1986 is amended to read as follows: 9
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‘‘(a) GENERALRULE.—For purposes of section 46, 1
the rehabilitation credit for any taxable year is 20 percent 2
of the qualified rehabilitation expenditures.’’. 3
(b) E
FFECTIVEDATE.—The amendment made by 4
this section shall apply to property placed in service after 5
December 31, 2023. 6
SEC. 3. INCREASE IN THE REHABILITATION CREDIT FOR 7
CERTAIN SMALL PROJECTS. 8
(a) I
NGENERAL.—Section 47 of the Internal Rev-9
enue Code of 1986 is amended by adding at the end the 10
following new subsection: 11
‘‘(e) S
PECIALRULEREGARDINGCERTAINSMALL 12
P
ROJECTS.— 13
‘‘(1) I
N GENERAL.—In the case of any quali-14
fying small project with respect to which there is an 15
election in effect under this subsection— 16
‘‘(A) the total qualified rehabilitation ex-17
penditures taken into account for purposes of 18
this section with respect to the rehabilitation 19
shall not exceed $3,750,000, 20
‘‘(B) subsection (a) shall be applied by 21
substituting ‘30 percent’ for ‘20 percent’, and 22
‘‘(C) subject to paragraph (4) and such 23
regulations or other guidance as the Secretary 24
may provide, the taxpayer may transfer all or 25
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a portion of the credit determined under this 1
section with respect to such qualifying small 2
project. 3
‘‘(2) Q
UALIFYING SMALL PROJECT .—For pur-4
poses of this subsection, the term ‘qualifying small 5
project’ means any qualified rehabilitated building or 6
portion thereof if— 7
‘‘(A) such building is placed in service 8
after the date of the enactment of this sub-9
section, and 10
‘‘(B) no credit was allowed under this sec-11
tion (other than a credits allowed by reason of 12
subsection (d)) for either of the two imme-13
diately preceding taxable years with respect to 14
such building. 15
‘‘(3) S
PECIAL RULE FOR RURAL PROJECTS .— 16
‘‘(A) I
N GENERAL.—In the case of any 17
qualifying small project in a rural area, para-18
graph (1)(A) shall be applied by substituting 19
‘$5,000,000’ for ‘$3,750,000’. 20
‘‘(B) R
URAL AREA.—For purposes of this 21
subparagraph, the term ‘rural area’ means any 22
area other than— 23
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‘‘(i) a city or town that has a popu-1
lation of greater than 50,000 inhabitants, 2
or 3
‘‘(ii) the urbanized area contiguous 4
and adjacent to a city or town described in 5
clause (i), as defined by the Bureau of the 6
Census based on the latest decennial cen-7
sus of the United States. 8
‘‘(4) T
RANSFER OF CREDIT FOR QUALIFYING 9
SMALL PROJECTS.— 10
‘‘(A) C
ERTIFICATION.— 11
‘‘(i) I
N GENERAL.—A transfer under 12
paragraph (1)(C) shall be accompanied by 13
a certificate which includes— 14
‘‘(I) the certification for the cer-15
tified historic structure referred to in 16
subsection (c)(3), 17
‘‘(II) the taxpayer’s name, ad-18
dress, tax identification number, date 19
of project completion, and the amount 20
of credit being transferred, 21
‘‘(III) the transferee’s name, ad-22
dress, tax identification number, and 23
the amount of credit being trans-24
ferred, and 25
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‘‘(IV) such other information as 1
may be required by the Secretary. 2
‘‘(ii) T
RANSFERABILITY OF CERTIFI -3
CATE.—A certificate issued under this sub-4
section to a taxpayer shall be transferable 5
to any other taxpayer. 6
‘‘(B) T
AX TREATMENT RELATING TO CER -7
TIFICATE.— 8
‘‘(i) D
ISALLOWANCE OF DEDUC -9
TION.—No deduction shall be allowed for 10
the amount of consideration paid or in-11
curred by the transferee. 12
‘‘(ii) A
LLOWANCE OF CREDIT .—The 13
amount of credit transferred under para-14
graph (1)(C)— 15
‘‘(I) shall not be allowed to the 16
transferor for any taxable year, and 17
‘‘(II) shall be allowable to the 18
transferee as a credit determined 19
under this section for the taxable year 20
of the transferee in which such credit 21
is transferred. 22
‘‘(iii) E
XCLUSION.—Gross income 23
shall not include any amount received in 24
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connection with the transfer of the certifi-1
cate. 2
‘‘(C) R
ECAPTURE AND OTHER SPECIAL 3
RULES.—The taxpayer who claims a credit de-4
termined under this section by reason of a 5
transfer of an amount of credit under para-6
graph (1)(A) with respect to an applicable rural 7
project shall be treated as the taxpayer with re-8
spect to such project for purposes of section 50. 9
‘‘(D) I
NFORMATION REPORTING .—The 10
transferor and the transferee shall each make 11
such reports regarding the transfer of an 12
amount of credit under paragraph (1)(C) and 13
containing such information as the Secretary 14
may require. The reports required by this sub-15
paragraph shall be filed at such time and in 16
such manner as may be required by the Sec-17
retary. 18
‘‘(E) R
EGULATIONS.—The Secretary shall 19
prescribe regulations or other guidance to carry 20
out paragraph (1)(C) and this paragraph in a 21
manner which is consistent with applicable re-22
quirements with respect to transfer of credits 23
under section 6418. 24
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‘‘(5) ELECTION.—An election under this sub-1
section shall be made at such time and in such man-2
ner as the Secretary may by regulations prescribe.’’. 3
(b) E
FFECTIVEDATE.—The amendment made by 4
this section shall apply to property placed in service after 5
the date of the enactment of this Act. 6
SEC. 4. INCREASING THE TYPE OF BUILDINGS ELIGIBLE 7
FOR REHABILITATION. 8
(a) I
NGENERAL.—Section 47(c)(1)(B)(i)(I) of the 9
Internal Revenue Code of 1986 is amended by inserting 10
‘‘50 percent of’’ before ‘‘the adjusted basis’’. 11
(b) E
FFECTIVEDATE.—The amendment made by 12
subsection (a) shall apply to property placed in service 13
after the date of the enactment of this Act. 14
SEC. 5. ELIMINATION OF REHABILITATION CREDIT BASIS 15
ADJUSTMENT. 16
(a) I
NGENERAL.—Section 50(c) of the Internal Rev-17
enue Code of 1986 is amended by adding at the end the 18
following new paragraph: 19
‘‘(6) E
XCEPTION FOR REHABILITATION CRED -20
IT.—In the case of the rehabilitation credit, para-21
graph (1) shall not apply.’’. 22
(b) T
REATMENT INCASE OFCREDITALLOWED TO 23
L
ESSEE.—Section 50(d) of such Code is amended by add-24
ing at the end the following: ‘‘In the case of the rehabilita-25
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tion credit, paragraph (5)(B) of the section 48(d) referred 1
to in paragraph (5) of this subsection shall not apply.’’. 2
(c) E
FFECTIVEDATE.—The amendments made by 3
this section shall apply to property placed in service after 4
the date of the enactment of this Act. 5
SEC. 6. MODIFICATIONS REGARDING CERTAIN TAX-EXEMPT 6
USE PROPERTY. 7
(a) I
NGENERAL.—Section 47(c)(2)(B)(v) of the In-8
ternal Revenue Code of 1986 is amended by adding at the 9
end the following new subclause: 10
‘‘(III) D
ISQUALIFIED LEASE 11
RULES TO APPLY ONLY IN CASE OF 12
GOVERNMENT ENTITY .—For purposes 13
of subclause (I), except in the case of 14
a tax-exempt entity described in sec-15
tion 168(h)(2)(A)(i), the determina-16
tion of whether property is tax-exempt 17
use property shall be made under sec-18
tion 168(h) without regard to whether 19
the property is leased in a disqualified 20
lease (as defined in section 21
168(h)(1)(B)(ii)).’’. 22
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(b) EFFECTIVEDATE.—The amendments made by 1
this section shall apply to property placed in service after 2
the date of the enactment of this Act. 3
Æ
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