119-s2664

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 2664 Introduced in Senate

    (IS) ]

<DOC>

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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