II
119THCONGRESS
1
STSESSION S. 1480
To amend the Internal Revenue Code of 1986 to provide a credit to issuers
of American infrastructure bonds.
IN THE SENATE OF THE UNITED STATES
APRIL10, 2025
Mr. W
ICKER(for himself, Mr. BENNET, Mrs. BRITT, and Mrs. HYDE-SMITH)
introduced the following bill; which was read twice and referred to the
Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to provide
a credit to issuers of American infrastructure bonds.
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 ‘‘American Infrastruc-4
ture Bonds Act of 2025’’. 5
SEC. 2. CREDIT FOR AMERICAN INFRASTRUCTURE BONDS 6
ALLOWED TO ISSUERS. 7
(a) I
NGENERAL.—Subchapter B of chapter 65 of the 8
Internal Revenue Code of 1986 is amended by inserting 9
after section 6430 the following new section: 10
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‘‘SEC. 6431. CREDIT TO ISSUER OF AMERICAN INFRASTRUC-1
TURE BONDS. 2
‘‘(a) I
NGENERAL.—The issuer of an American infra-3
structure bond shall be allowed a credit with respect to 4
each interest payment under such bond which shall be pay-5
able by the Secretary as provided in subsection (b). 6
‘‘(b) P
AYMENT OFCREDIT.— 7
‘‘(1) I
N GENERAL.—The Secretary shall pay 8
(contemporaneously with each interest payment date 9
under such bond) to the issuer of such bond (or to 10
any person who makes such interest payments on 11
behalf of the issuer) 28 percent of the interest pay-12
able under such bond on such date. 13
‘‘(2) I
NTEREST PAYMENT DATE .—For purposes 14
of this subsection, the term ‘interest payment date’ 15
means each date on which the holder of record of 16
the American infrastructure bond is entitled to a 17
payment of interest under such bond. 18
‘‘(c) A
MERICANINFRASTRUCTURE BOND.— 19
‘‘(1) I
N GENERAL.—For purposes of this sec-20
tion, the term ‘American infrastructure bond’ means 21
any obligation if— 22
‘‘(A) the interest on such obligation would 23
(but for this section) be excludable from gross 24
income under section 103, 25
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‘‘(B) the obligation is not a private activity 1
bond, and 2
‘‘(C) the issuer makes an irrevocable elec-3
tion to have this section apply. 4
‘‘(2) A
PPLICABLE RULES.—For purposes of ap-5
plying paragraph (1)— 6
‘‘(A) for purposes of section 149(b), a 7
bond shall not be treated as federally guaran-8
teed by reason of the credit allowed under this 9
section, and 10
‘‘(B) a bond shall not be treated as an 11
American infrastructure bond if the issue price 12
has more than a de minimis amount (deter-13
mined under rules similar to the rules of section 14
1273(a)(3)) of premium over the stated prin-15
cipal amount of the bond. 16
‘‘(d) S
PECIALRULES.— 17
‘‘(1) I
NTEREST ON AMERICAN INFRASTRUC -18
TURE BONDS INCLUDIBLE IN GROSS INCOME FOR 19
FEDERAL INCOME TAX PURPOSES .—For purposes of 20
this title, interest on any American infrastructure 21
bond shall be includible in gross income. 22
‘‘(2) A
PPLICATION OF ARBITRAGE RULES .—For 23
purposes of section 148, the yield on an issue of 24
American infrastructure bonds shall be reduced by 25
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the credit allowed under this section, except that no 1
such reduction shall apply with respect to deter-2
mining the amount of gross proceeds of an issue 3
that qualifies as a reasonably required reserve or re-4
placement fund. 5
‘‘(e) R
EGULATIONS.—The Secretary may prescribe 6
such regulations and other guidance as may be necessary 7
or appropriate to carry out this section.’’. 8
(b) C
ONFORMINGAMENDMENTS.— 9
(1) The table of sections for subchapter B of 10
chapter 65 of subtitle F of the Internal Revenue 11
Code of 1986 is amended by adding at the end the 12
following new item: 13
‘‘Sec. 6431. Credit to issuer of american infrastructure bonds.’’.
(2) Subparagraph (A) of section 6211(b)(4) of 14
such Code is amended by inserting ‘‘6431,’’ after 15
‘‘6428B,’’. 16
(c) T
RANSITIONALCOORDINATION WITHSTATE 17
L
AW.—Except as otherwise provided by a State after the 18
date of the enactment of this Act, the interest on any 19
American infrastructure bond (as defined in section 6431 20
of the Internal Revenue Code of 1986 (as added by this 21
Act)) and the amount of any credit determined under such 22
section with respect to such bond shall be treated for pur-23
poses of the income tax laws of such State as being exempt 24
from Federal income tax. 25
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(d) ADJUSTMENT TOPAYMENT TOISSUERS INCASE 1
OFSEQUESTRATION.— 2
(1) I
N GENERAL.—In the case of any payment 3
under subsection (b) of section 6431 of the Internal 4
Revenue Code of 1986 (as added by this Act) made 5
after the date of enactment of this Act to which se-6
questration applies, the amount of such payment 7
shall be increased to an amount equal to— 8
(A) such payment (determined before such 9
sequestration), multiplied by 10
(B) the quotient obtained by dividing the 11
number 1 by the amount by which the number 12
1 exceeds the percentage reduction in such pay-13
ment pursuant to such sequestration. 14
(2) S
EQUESTRATION.—For purposes of this 15
subsection, the term ‘‘sequestration’’ means any re-16
duction in direct spending ordered in accordance 17
with a sequestration report prepared by the Director 18
of the Office and Management and Budget pursuant 19
to the Balanced Budget and Emergency Deficit Con-20
trol Act of 1985 or the Statutory Pay-As-You-Go 21
Act of 2010 or future legislation having similar ef-22
fect. 23
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(e) EFFECTIVEDATE.—The amendments made by 1
this section shall apply to obligations issued after the date 2
of enactment of this Act. 3
Æ
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