[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 2664 Introduced in Senate (IS)]
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119th CONGRESS
1st Session
S. 2664
To amend the Internal Revenue Code of 1986 to establish the qualifying
workforce training project credit.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
August 1, 2025
Mr. Ossoff 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 establish the qualifying
workforce training project credit.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Skilled Workforce Act''.
SEC. 2. ESTABLISHMENT OF QUALIFYING WORKFORCE TRAINING PROJECT CREDIT.
(a) In General.--Subpart E of part IV of subchapter A of chapter 1
of the Internal Revenue Code of 1986 is amended by inserting after
section 48E the following new section:
``SEC. 48F. QUALIFYING WORKFORCE TRAINING PROJECT CREDIT.
``(a) Establishment of Credit.--
``(1) In general.--For purposes of section 46, the
qualifying workforce training project credit for any taxable
year is an amount equal to 30 percent of the qualified
investment for such taxable year with respect to any qualifying
workforce training project of an eligible taxpayer.
``(2) Eligible taxpayer.--For purposes of this section, the
term `eligible taxpayer' means any taxpayer which is not a
foreign entity of concern (as defined in section 9901(8) of the
William M. (Mac) Thornberry National Defense Authorization Act
for Fiscal Year 2021 (15 U.S.C. 4651(8))).
``(b) Qualified Investment.--
``(1) In general.--For purposes of subsection (a), the
qualified investment for any taxable year is the basis of
eligible property placed in service by the eligible taxpayer
during such taxable year which is part of a qualifying
workforce training project.
``(2) Certain qualified progress expenditure rules made
applicable.--Rules similar to the rules of subsections (c)(4)
and (d) of section 46 (as in effect on the day before the
enactment of the Revenue Reconciliation Act of 1990) shall
apply for purposes of this section.
``(3) Limitation.--The amount which is treated as the
qualified investment for all taxable years with respect to any
qualifying workforce training project shall not exceed the
amount designated by the Secretary as eligible for the credit
under this section.
``(c) Definitions.--In this section--
``(1) Qualifying workforce training project.--The term
`qualifying workforce training project' means a project, any
portion of the qualified investment of which is certified by
the Secretary (in consultation with the Secretary of Commerce)
under subsection (d) as eligible for a credit under this
section, which equips, expands, or enhances an eligible
institution to address workforce shortages and skills gaps with
respect to in-demand jobs and industries (as identified by the
Secretary), including--
``(A) advanced, high-tech, semiconductor, and
industrial manufacturing,
``(B) advanced energy (such as hydrogen, nuclear,
and solar),
``(C) construction, and
``(D) transportation, including aviation,
aerospace, airports, and advanced air mobility.
``(2) Eligible property.--The term `eligible property'
means any property--
``(A) which is necessary for construction,
renovation, or infrastructure upgrades with respect to
the campus and facilities of an eligible institution
which will, in the judgment of the Secretary, expand
high-quality, in-demand, skills-based training,
programming, and workforce opportunities,
``(B) which is--
``(i) tangible personal property,
``(ii) other tangible property (including a
building and its structural components), but
only if such property is used as an integral
part of the eligible institution, or
``(iii) intangible property (as defined in
section 367(d)(4)), including digital or
virtual learning platforms and associated
equipment, but only if such property is used as
an integral part of any property described in
clause (i) and the eligible institution, and
``(C) with respect to which depreciation (or
amortization in lieu of depreciation) is allowable.
``(3) Eligible institution.--
``(A) In general.--The term `eligible institution'
means an entity that is (and was, as of the day before
the date of enactment of this Act)--
``(i) a public secondary school or a local
educational agency,
``(ii) an area career and technical
education school (as defined in section 3 of
the Carl D. Perkins Career and Technical
Education Act of 2006 (20 U.S.C. 2302))--
``(I) that is a public school, and
``(II) at which the most frequently
awarded degree is not a bachelor's
degree,
``(iii) a postsecondary vocational
institution (as defined in section 102(c) of
the Higher Education Act of 1965 (20 U.S.C.
1002(c)))--
``(I) that is a public institution,
and
``(II) at which the most frequently
awarded degree is not a bachelor's
degree,
``(iv) a community college,
``(v) a State-operated workforce
development program, or
``(vi) a consortium of entities described
in clauses (i) through (v).
``(B) Community college.--The term `community
college' means--
``(i) a public institution of higher
education (as defined in section 101(a) of the
Higher Education Act of 1965 (20 U.S.C.
1001(a))), at which--
``(I) the highest degree awarded is
an associate degree, or
``(II) an associate degree is the
most frequently awarded degree, or
``(ii) a Tribal College or University (as
defined in section 316(b) of the Higher
Education Act of 1965 (20 U.S.C. 1059c(b)))--
``(I) that is a 2-year Tribal
College or University,
``(II) at which the highest degree
awarded is an associate degree, or
``(III) at which an associate
degree is the most frequently awarded
degree.
``(4) Public secondary school.--The term `public secondary
school' means a public secondary school, as defined in section
8101 of the Elementary and Secondary Education Act of 1965 (20
U.S.C. 7801), that includes any of grades 9 through 12.
``(d) Qualifying Workforce Training Project Program.--
``(1) Establishment.--
``(A) In general.--Not later than 180 days after
the date of enactment of this section, the Secretary,
in consultation with the Secretary of Commerce, shall
establish a qualifying workforce training project
program to consider and award certifications for
qualified investments eligible for credits under this
section to qualifying workforce training project
sponsors.
``(B) Limitation.--The total amount of credits that
may be allocated under the program shall not exceed
$500,000,000, of which not greater than $400,000,000
may be allocated to qualified investments with respect
to any qualifying workforce training project which does
not involve an eligible institution which is one or
more of the following:
``(i) A public secondary school that is
eligible to receive assistance under part A of
title I of the Elementary and Secondary
Education Act of 1965 (20 U.S.C. 6311 et seq.).
``(ii) A rural public secondary school.
``(iii) A public secondary school funded by
the Bureau of Indian Education.
``(iv) A local educational agency that will
support a qualifying workforce training project
involving a school described in clause (i) or
(ii).
``(2) Certification.--
``(A) Application period.--Each applicant for
certification under this paragraph shall submit an
application containing such information as the
Secretary may require during the 4-year period
beginning on the date the Secretary establishes the
program under paragraph (1).
``(B) Time to meet criteria for certification.--
Each applicant for certification shall have 1 year from
the date of acceptance by the Secretary of the
application during which to provide to the Secretary
evidence that the requirements of the certification
have been met.
``(C) Period of issuance.--An applicant which
receives a certification shall have 3 years from the
date of issuance of the certification in order to place
the project in service and if such project is not
placed in service by that time period, then the
certification shall no longer be valid.
``(3) Selection criteria.--In determining which qualifying
workforce training projects to certify under this section, the
Secretary shall take into consideration which projects--
``(A) satisfy current or expected State or regional
workforce development requirements,
``(B) build in-demand training program pipelines
which maximize the skill level of, and expand
opportunities for high-quality employment for, the
State or regional workforce,
``(C) demonstrate financial sustainability of the
project in the geographic region in which it is
located, and
``(D) provide accommodations to individuals
enrolled at the eligible institution to receive
supportive services or propose to directly provide such
services to individuals enrolled at the eligible
institution.
``(4) Review and redistribution; disclosure of
allocations.--Rules similar to rules under paragraphs (4) and
(5) of section 48C(d) shall apply for purposes of this section.
``(e) Denial of Double Benefit.--In the case of any qualified
investment for which a credit is allowed under this section--
``(1) no deduction shall be allowed under section 170 with
respect to such investment, and
``(2) no credit shall be allowed under any other provision
of this chapter with respect to such investment.''.
(b) Elective Payment and Transfer of Credit.--
(1) Elective payment.--Section 6417(b) of the Internal
Revenue Code of 1986 is amended by adding at the end the
following:
``(13) The qualifying workforce training project credit
under section 48F.''.
(2) Transfer.--Section 6418(f)(1)(A) of the Internal
Revenue Code of 1986, as amended by section 70521 of Public Law
119-21, is amended by adding at the end the following:
``(xiii) The qualifying workforce training
project credit under section 48F.''.
(c) Conforming Amendments.--
(1) Section 46 of the Internal Revenue Code of 1986 is
amended--
(A) in paragraph (6), by striking ``and'' at the
end,
(B) in paragraph (7), by striking the period at the
end and inserting ``, and'', and
(C) by adding at the end the following:
``(8) the qualifying workforce training project credit.''.
(2) Section 49(a)(1)(C) of such Code is amended--
(A) in clause (vii), by striking ``and'' at the
end,
(B) in clause (viii), by striking the period at the
end and inserting ``, and'', and
(C) by adding at the end the following:
``(ix) the basis of any eligible property
which is part of a qualifying workforce
training project credit under section 48F.''.
(3) Section 50(a)(2)(E) of such Code is amended by striking
``or 48E(e)'' and inserting ``48E(e), or 48F(b)(2)''.
(4) The table of sections for subpart E of part IV of
subchapter A of chapter 1 of such Code is amended by inserting
after the item relating to section 48E the following new item:
``Sec. 48F. Qualifying workforce training project credit.''.
(d) Authorization of Appropriations.--There are authorized to be
appropriated, out of moneys in the Treasury not otherwise appropriated,
such sums as may be necessary for the Department of the Treasury and
the Department of Commerce to administer section 48F of the Internal
Revenue Code of 1986 (as added by this Act).
(e) Effective Date.--The amendments made by this section shall
apply to property placed in service during any taxable year beginning
after the date of enactment of this Act.
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