S. 2664

[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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