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119-s-1459119th CongressWALLET

Historic Tax Credit Growth and Opportunity Act of 2025

Sponsored By: Senator Cassidy, Bill [R-LA]

Introduced

Summary

Boosts the Historic Rehabilitation Tax Credit and makes small projects' credits transferable. This bill would raise the credit's usability and expand which costs and buildings qualify to spur more investment in historic rehabilitation.

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  • Owners and developers of historic properties would see the base rehabilitation credit set at 20% of qualified rehabilitation costs and the law would treat that credit as fully available in the year a property is placed in service for eligible projects. It also increases the portion of a building's basis counted toward the credit by adding 50% of adjusted basis into the computation and removes the rehabilitation credit basis adjustment for applicable properties.
  • Qualifying small projects would get a higher 30% credit with a project cap of $3.8 million, and qualifying rural small projects would get a $5.0 million cap. The bill lets small projects elect into these rules under guidance from the Treasury.
  • The bill creates a detailed transfer framework for qualifying small-project credits so owners can transfer all or part of the credit to buyers. The framework includes certification, reporting, recapture rules, and tax treatment that lets the transferee claim the credit while the transferor gets no deduction and does not recognize the transfer as gross income.
  • For tax-exempt use property the bill narrows disqualified lease rules to apply only to government entities with an exception for certain tax-exempt organizations and says whether property is tax-exempt use property is determined under existing Section 168(h) rules without regard to disqualified leases.

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Bill Overview

Analyzed Economic Effects

3 provisions identified: 3 benefits, 0 costs, 0 mixed.

Bigger rehab credit and basis boost

If enacted, you would be able to claim a 20% rehabilitation tax credit on qualified rehab costs for eligible property placed in service after December 31, 2023. The bill would let you treat 50% of a property's adjusted basis as the eligible basis when figuring the credit for property placed in service after enactment. It would also prevent the usual section 50 basis-reduction rules from applying to the rehabilitation credit for property placed in service after enactment.

New 30% small-project credit

If enacted, you would be able to elect a "qualifying small project" rule that gives a 30% rehabilitation credit for eligible projects placed in service after enactment. The credit would apply to up to $3,750,000 of rehab costs per project, or up to $5,000,000 if the project is in a defined rural area; that yields up to $1,125,000 or $1,500,000 in credit. The bill would let you transfer (sell) all or part of the credit using a certificate system. Transfer rules would include reporting, exclude amounts received from gross income, and include recapture and regulations as specified.

Narrow disqualified-lease rule

If enacted, the bill would limit the "disqualified lease" rules so they apply only when the lessee is a government entity. Except for certain tax-exempt entities in section 168(h)(2)(A)(i), Treasury would determine tax-exempt use status under section 168(h) without regard to whether the property is leased in a disqualified lease. The change would apply to property placed in service after enactment and could make more owners eligible for the rehab credit when leasing to non-government tax-exempt entities.

Sponsors & CoSponsors

Sponsor

Cassidy, Bill [R-LA]

LA • R

Cosponsors

  • Sen. Warner, Mark R. [D-VA]

    VA • D

    Sponsored 4/10/2025

  • Sen. Collins, Susan M. [R-ME]

    ME • R

    Sponsored 4/10/2025

  • Sen. Cantwell, Maria [D-WA]

    WA • D

    Sponsored 4/10/2025

  • Sen. Klobuchar, Amy [D-MN]

    MN • D

    Sponsored 5/6/2025

  • Sen. Hyde-Smith, Cindy [R-MS]

    MS • R

    Sponsored 5/8/2025

  • Sen. Smith, Tina [D-MN]

    MN • D

    Sponsored 6/2/2025

  • Sen. Banks, Jim [R-IN]

    IN • R

    Sponsored 6/2/2025

  • Sen. Young, Todd [R-IN]

    IN • R

    Sponsored 2/24/2026

  • Sen. King, Angus S., Jr. [I-ME]

    ME • I

    Sponsored 3/3/2026

  • Sen. Capito, Shelley Moore [R-WV]

    WV • R

    Sponsored 6/15/2026

  • Sen. Alsobrooks, Angela D. [D-MD]

    MD • D

    Sponsored 6/15/2026

  • Sen. Justice, James C. [R-WV]

    WV • R

    Sponsored 6/22/2026

  • Sen. Whitehouse, Sheldon [D-RI]

    RI • D

    Sponsored 6/23/2026

Roll Call Votes

No roll call votes available for this bill.

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