I 

118TH CONGRESS 

2D SESSION H. R. 10147 

To amend the Internal Revenue Code of 1986 to allow for a credit against 

tax for employers of reservists. 

IN THE HOUSE OF REPRESENTATIVES 

NOVEMBER 15, 2024 

Ms. PLASKETT introduced the following bill; which was referred to the 

Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to allow for 

a credit against tax for employers of reservists. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Reserve Employers 

5 Comprehensive Relief and Uniform Incentives on Taxes 

6 Act of 2024’’ or as the ‘‘RECRUIT Act of 2024’’. 

7 SEC. 2. RESERVIST EMPLOYMENT CREDIT. 

8 (a) ALLOWANCE OF CREDIT.—Subpart D of part IV 

9 of subchapter A of chapter 1 of the Internal Revenue Code 


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1 of 1986 is amended by adding at the end the following 

2 new section: 

3 ‘‘SEC. 45BB. RESERVIST EMPLOYMENT CREDIT. 

4 ‘‘(a) ESTABLISHMENT OF CREDIT.—For purposes of 

5 section 38, in the case of an eligible employer, the reservist 

6 employment credit for any taxable year is an amount equal 

7 to 40 percent of the wages paid or incurred to qualified 

8 reservists by such employer during such taxable year. 

9 ‘‘(b) LIMITATION.— 

10 ‘‘(1) IN GENERAL.—The reservist employment 

11 credit determined under subsection (a), with respect 

12 to any qualified reservist for any taxable year, shall 

13 not exceed the reservist credit amount. 

14 ‘‘(2) RESERVIST CREDIT AMOUNT.—For pur15 poses of this section, the term ‘reservist credit 

16 amount’ means, with respect to a qualified reservist 

17 for a taxable year, an amount equal to the sum of— 

18 ‘‘(A) $1,000, plus 

19 ‘‘(B) in the case of a qualified reservist— 

20 ‘‘(i) with 30 or more days, and fewer 

21 than 90 days, of service in the uniformed 

22 services during such year, $3,000, 

23 ‘‘(ii) with 90 or more days, and fewer 

24 than 180 days, of service in the uniformed 

25 services during such year, $5,000, and 


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1 ‘‘(iii) with 180 or more days of service 

2 in the uniformed services during such year, 

3 $10,000. 

4 ‘‘(3) DAYS OF SERVICE.—For purposes of para5 graph (2), any day of service— 

6 ‘‘(A) shall not be taken into account if 

7 such day constitutes inactive-duty training, or 

8 active duty or full-time National Guard duty for 

9 a period of 30 days or less, and 

10 ‘‘(B) shall only be taken into account with 

11 respect to a qualified reservist employed by an 

12 eligible employer to the extent such days are 

13 during a period of employment of such reservist 

14 by such employer. 

15 ‘‘(4) QUALIFIED RESERVIST.—The term ‘quali16 fied reservist’ means, with respect to a taxable year, 

17 an individual who is, at any time during such tax18 able year, a member of the National Guard or a re19 serve component of the Armed Forces, as named in 

20 section 10101 of title 10, United States Code, in ac21 tive status. 

22 ‘‘(5) RESERVE COMPONENT.—The term ‘reserve 

23 component’ means any of the reserve components of 

24 the Armed Forces named in section 10101 of title 

25 10, United States Code. 


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1 ‘‘(6) NATIONAL GUARD.—The term ‘National 

2 Guard’ has the meaning given such term in section 

3 101(3) of title 32, United States Code. 

4 ‘‘(7) SERVICE IN THE UNIFORMED SERVICES.— 

5 The term ‘service in the uniformed services’ means 

6 active duty or full-time National Guard duty for a 

7 period of more than 30 days, but does not include 

8 active Guard and Reserve duty. 

9 ‘‘(8) ACTIVE STATUS.—The term ‘active status’ 

10 has the meaning given such term in section 101 of 

11 title 10, United States Code. 

12 ‘‘(9) INACTIVE-DUTY TRAINING.—The term ‘in13 active-duty training’ has the meaning given such 

14 term in section 101 of title 10, United States Code. 

15 ‘‘(c) ELIGIBLE EMPLOYER.—For purposes of this 

16 section, the term ‘eligible employer’ means any employer 

17 which— 

18 ‘‘(1) has an average of less than 500 employees 

19 employed on business days during the taxable year, 

20 ‘‘(2) meets the gross receipts test of section 

21 448(c) for the taxable year, and 

22 ‘‘(3) is not a tax shelter prohibited from using 

23 the cash receipts and disbursements method of ac24 counting under section 448(a)(3). 


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1 In the case of any taxpayer which is not a corporation 

2 or partnership, the gross receipts test of section 448(c) 

3 shall, for purposes of paragraph (2) of this subsection, be 

4 applied in the same manner as if such taxpayer were a 

5 corporation or partnership. 

6 ‘‘(d) AGGREGATION RULE.—All persons treated as a 

7 single employer under subsection (b), (c), (m), or (o) of 

8 section 414 shall be treated as 1 employer for purposes 

9 of this section. 

10 ‘‘(e) ELECTION TO HAVE CREDIT NOT APPLY.— 

11 ‘‘(1) IN GENERAL.—A taxpayer may elect to 

12 have this section not apply for any taxable year. 

13 ‘‘(2) OTHER RULES.—Rules similar to the rules 

14 of paragraphs (2) and (3) of section 51(j) shall 

15 apply for purposes of this subsection.’’. 

16 (b) CREDIT PART OF GENERAL BUSINESS CREDIT.— 

17 Section 38(b) of the Internal Revenue Code of 1986 is 

18 amended by striking ‘‘plus’’ at the end of paragraph (40), 

19 by striking the period at the end of paragraph (41) and 

20 inserting ‘‘, plus’’, and by adding at the end the following 

21 new paragraph: 

22 ‘‘(42) in the case of an eligible employer (as de23 fined in section 45BB(c)), the reservist employment 

24 credit determined under section 45BB(a).’’. 


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1 (c) CREDIT ALLOWED AGAINST AMT.—Subpara2 graph (B) of section 38(c)(4) of the Internal Revenue 

3 Code of 1986 is amended by redesignating clauses (x) 

4 through (xii) as clauses (xi) through (xiii), respectively, 

5 and by inserting after clause (ix) the following new clause: 

6 ‘‘(x) the credit determined under sec7 tion 45BB,’’. 

8 (d) CONFORMING AMENDMENTS.— 

9 (1) DENIAL OF DOUBLE BENEFIT.—Section 

10 280C(a) of the Internal Revenue Code of 1986 is 

11 amended by inserting ‘‘45BB(a),’’ after ‘‘45S(a),’’. 

12 (2) ELECTION TO HAVE CREDIT NOT APPLY.— 

13 Section 6501(m) of the Internal Revenue Code of 

14 1986 is amended by inserting ‘‘45BB(d),’’ after 

15 ‘‘45H(g),’’. 

16 (3) CLERICAL AMENDMENT.—The table of sec17 tions for subpart D of part IV of subchapter A of 

18 chapter 1 of the Internal Revenue Code of 1986 is 

19 amended by adding at the end the following new 

20 item: 

‘‘Sec. 45BB. Reservist employment credit.’’. 

21 (e) TREATMENT OF POSSESSIONS.— 

22 (1) PAYMENTS TO POSSESSIONS.— 

23 (A) MIRROR CODE POSSESSIONS.—The 

24 Secretary of the Treasury shall pay to each pos25 session of the United States with a mirror code 


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1 tax system amounts equal to the loss to that 

2 possession by reason of the amendments made 

3 by this section. Such amounts shall be deter4 mined by the Secretary of the Treasury based 

5 on information provided by the government of 

6 the respective possession of the United States. 

7 (B) OTHER POSSESSIONS.—The Secretary 

8 of the Treasury shall pay to each possession of 

9 the United States which does not have a mirror 

10 code tax system the amount estimated by the 

11 Secretary of the Treasury as being equal to the 

12 loss to that possession that would have occurred 

13 by reason of the amendments made by this sec14 tion if a mirror code tax system had been in ef15 fect in such possession. The preceding sentence 

16 shall not apply with respect to any possession 

17 of the United States unless such possession es18 tablishes to the satisfaction of the Secretary 

19 that the possession has implemented (or, at the 

20 discretion of the Secretary, will implement) an 

21 income tax benefit which is substantially equiv22 alent to the income tax credit in effect after the 

23 amendments made by this section. 

24 (2) COORDINATION WITH CREDIT ALLOWED

25 AGAINST UNITED STATES INCOME TAXES.—The 


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1 credit allowed under section 45BB of the Internal 

2 Revenue Code of 1986 (as added by this section) to 

3 any eligible employer with respect to any qualified 

4 reservist shall be reduced by the amount of any 

5 credit (or other tax benefit described in paragraph 

6 (1)(B)) against income taxes imposed by a posses7 sion of the United States allowed to such employer 

8 with respect to such reservist by reason of this sec9 tion for the taxable year. 

10 (3) DEFINITIONS AND SPECIAL RULES.— 

11 (A) POSSESSION OF THE UNITED

12 STATES.—For purposes of this subsection, the 

13 term ‘‘possession of the United States’’ shall in14 clude such possessions as are specified in sec15 tion 937(a)(1) of the Internal Revenue Code of 

16 1986. 

17 (B) MIRROR CODE TAX SYSTEM.—For pur18 poses of this subsection, the term ‘‘mirror code 

19 tax system’’ means, with respect to any posses20 sion of the United States, the income tax sys21 tem of such possession if the income tax liabil22 ity of the residents of such possession under 

23 such system is determined by reference to the 

24 income tax laws of the United States as if such 

25 possession were the United States. 


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1 (C) TREATMENT OF PAYMENTS.—For pur2 poses of section 1324(b)(2) of title 31, United 

3 States Code, the payments under this sub4 section shall be treated in the same manner as 

5 a refund due from credit provisions described in 

6 such section. 

7 (f) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to wages paid in taxable years be9 ginning after December 31, 2023. 

Æ 


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