“To amend the Internal Revenue Code of 1986 to provide for school infrastructure finance and innovation tax credit bonds.”
No CRS summary available for this bill.
This section establishes a new tax credit under new IRC §54BB for holders of qualified SIFIA bonds, equal to 25% of the annual credit (applicable credit rate times outstanding face amount, with the rate set by the Secretary to permit issuance at par) on each quarterly credit allowance date (March 15, June 15, September 15, December 15, or final maturity). The credit is limited to a taxpayer's regular tax liability plus alternative minimum tax (less other nonrefundable credits, excluding subpart C), with unused credits carried forward indefinitely. SIFIA bonds are tax-exempt private activity bonds (under IRC §103) designated for 100% financing of the design, construction, expansion, renovation, furnishing, or equipping of net-zero energy qualified school facilities through public-private partnerships, where a for-profit entity constructs and temporarily operates the facilities before transferring them to a state or local educational agency for no additional consideration; bonds must meet a 6-year expenditure requirement (with mandatory redemption of nonqualified amounts), private entity allocation and reporting rules, de minimis premium limits, and issuance before January 1, 2031. The aggregate face amount of designated SIFIA bonds is capped at $10 billion nationally ($2.5 billion per calendar year), with a $1 billion set-aside for rural areas (i.e., outside metropolitan statistical areas or as determined by the Secretary of Agriculture).