II 

115TH CONGRESS 

1ST SESSION S. 1193 

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

employer-provided job training, and for other purposes. 

IN THE SENATE OF THE UNITED STATES 

MAY 22, 2017 

Mr. MENENDEZ 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 provide 

a credit for employer-provided job training, and for other 

purposes. 

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 ‘‘Better Education and 

5 Skills Training for America’s Workforce Act’’. 

6 SEC. 2. JOB TRAINING TAX CREDIT. 

7 (a) IN GENERAL.—Subpart D of part IV of sub8 chapter A of chapter 1 of the Internal Revenue Code of 

9 1986 is amended by adding at the end the following new 

10 section: 


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1 ‘‘SEC. 45S. JOB TRAINING CREDIT. 

2 ‘‘(a) IN GENERAL.—For the purposes of section 38, 

3 the job training credit determined under this section for 

4 the taxable year is an amount equal to 100 percent of the 

5 qualified training expenses paid by the qualifying taxpayer 

6 during the taxable year. 

7 ‘‘(b) LIMITATION.—The credit allowed under sub8 section (a) with respect to any eligible trainee of the quali9 fying taxpayer shall not exceed the excess (if any) of 

10 $4,000 over the aggregate credit allowed to such taxpayer 

11 under this section with respect to such eligible trainee for 

12 all prior taxable years. 

13 ‘‘(c) DEFINITIONS.—For purposes of this section— 

14 ‘‘(1) QUALIFIED TRAINING EXPENSES.— 

15 ‘‘(A) IN GENERAL.—The term ‘qualified 

16 training expenses’ means, with respect to any 

17 eligible trainee of the qualifying taxpayer, ex18 penses paid or incurred by such taxpayer for 

19 qualified tuition costs of such eligible trainee. 

20 ‘‘(B) QUALIFIED TUITION COSTS.—The 

21 term ‘qualified tuition costs’ means costs for 

22 books and enrollment in a training program at 

23 a qualified educational organization, the out24 come of which, if completed, will provide the eli25 gible trainee a certificate or credential recog26 nized by a State accrediting body, Federal ApVerDate Sep 11 2014 23:24 May 30, 2017 Jkt 069200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\S1193.IS S1193

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1 prenticeship Agency, or any other national ac2 crediting body recognized by the Department of 

3 Education as an independent, third-party ac4 crediting body. Such training program— 

5 ‘‘(i) may include a single course, mul6 tiple courses, or a combination of work 

7 training and study, and 

8 ‘‘(ii) must be reasonably necessary for 

9 employment with the qualifying taxpayer. 

10 ‘‘(C) QUALIFIED EDUCATIONAL ORGANIZA11 TION.—The term ‘qualified educational organi12 zation’ means any educational organization de13 scribed in section 101 of the Higher Education 

14 Act of 1965. 

15 ‘‘(2) QUALIFYING TAXPAYER.—The term ‘quali16 fying taxpayer’ means any taxpayer who— 

17 ‘‘(A) with respect to any eligible trainee, is 

18 training and hiring individuals for positions 

19 based in the United States, and 

20 ‘‘(B) provides, with respect to any eligible 

21 trainee, such documentation as required by the 

22 Secretary regarding qualified training expenses 

23 and proof of unemployment status as described 

24 in paragraph (3)(A). 


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1 ‘‘(3) ELIGIBLE TRAINEE.—The term ‘eligible 

2 trainee’ means any individual who— 

3 ‘‘(A) has been unemployed for at least 90 

4 days before the date of enrollment in a training 

5 program described in paragraph (1)(B), and 

6 ‘‘(B) had not been employed by the quali7 fying taxpayer at any time during the 2-year 

8 period preceding the date on which such trainee 

9 was hired. 

10 ‘‘(d) SPECIAL RULES.— 

11 ‘‘(1) DENIAL OF DOUBLE BENEFIT.—No credit 

12 shall be allowed under subsection (a) for any quali13 fied training expense for which a deduction or other 

14 credit is allowed to the taxpayer under any other 

15 provision of this chapter. 

16 ‘‘(2) AGGREGATION.—For purposes of this sec17 tion, all persons treated as a single employer under 

18 subsection (a) or (b) or section 52, or subsection (m) 

19 or (o) of section 414, shall be treated as one person. 

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

21 taxpayer may elect (at such time and in such manner as 

22 the Secretary may by regulations prescribe) to have this 

23 section not apply for any taxable year. 

24 ‘‘(f) TERMINATION.—This section shall not apply to 

25 expenses paid after December 31, 2028.’’. 


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1 (b) CREDIT TO BE PART OF GENERAL BUSINESS

2 CREDIT.—Subsection (b) of section 38 of the Internal 

3 Revenue Code of 1986 is amended by striking ‘‘plus’’ at 

4 the end of paragraph (35), by striking the period at the 

5 end of paragraph (36) and inserting ‘‘, plus’’, and by add6 ing at the end the following new paragraph: 

7 ‘‘(37) the job training credit determined under 

8 section 45S(a).’’. 

9 (c) CREDIT ALLOWED AGAINST ALTERNATIVE MIN10 IMUM TAX.—Section 38(c)(4)(B) of the Internal Revenue 

11 Code of 1986 is amended by redesignating clauses (ix), 

12 (x), and (xi) as clauses (x), (xi), and (xii), respectively, 

13 and by inserting after clause (viii) the following new 

14 clause: 

15 ‘‘(ix) the credit determined under sec16 tion 45S,’’. 

17 (d) TECHNICAL AMENDMENT.—Section 6501(m) of 

18 the Internal Revenue Code of 1986 is amended by insert19 ing ‘‘45S(e),’’ after ‘‘45H(g),’’. 

20 (e) CLERICAL AMENDMENT.—The table of sections 

21 for subpart D of part IV of subchapter A of chapter 1 

22 of such Code is amended by adding at the end the fol23 lowing new item: 

‘‘Sec. 45S. Job training credit.’’. 

24 (f) REPORT.—Not later than January 1, 2027, the 

25 Secretary of the Treasury (or the Secretary’s delegate) 


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1 shall report to the Committee on Ways and Means of the 

2 House of Representatives and the Committee on Finance 

3 of the Senate on the economic impact of the job training 

4 credit under section 45S of the Internal Revenue Code of 

5 1986 (as added under subsection (a)). 

6 (g) EFFECTIVE DATES.— 

7 (1) IN GENERAL.—The amendments made by 

8 this section shall apply to expenses paid or incurred 

9 after the date of the enactment of this Act, in tax10 able years ending after such date. 

11 (2) MINIMUM TAX.—The amendments made by 

12 subsection (c) shall apply to credits determined 

13 under section 45S of the Internal Revenue Code of 

14 1986 in taxable years ending after the date of the 

15 enactment of this Act, and to carrybacks of such 

16 credits. 

17 SEC. 3. QUALIFIED JOB TRAINING PARTNERSHIP CREDIT. 

18 (a) IN GENERAL.—Subpart E of part IV of sub19 chapter A of chapter 1 of the Internal Revenue Code of 

20 1986 is amended by inserting after section 48D the fol21 lowing new section: 

22 ‘‘SEC. 48E. QUALIFIED JOB TRAINING PARTNERSHIP CRED23 IT. 

24 ‘‘(a) IN GENERAL.—For purposes of section 46, the 

25 Qualified Job Training Partnership credit for any taxable 


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1 year is an amount equal to the percentage determined by 

2 the Secretary (not to exceed 100 percent) of the qualified 

3 investment for such taxable year with respect to any 

4 Qualified Job Training Partnership. 

5 ‘‘(b) QUALIFIED INVESTMENT.— 

6 ‘‘(1) IN GENERAL.—For purposes of subsection 

7 (a), the qualified investment for any taxable year is 

8 the aggregate amount of the costs paid or incurred 

9 in such taxable year for expenses necessary for and 

10 directly related to the conduct of a Qualified Job 

11 Training Partnership in the form of contributions of 

12 cash, cash equivalent, equipment, or any combina13 tion of the three where 100 percent of the invest14 ment is used for the planning, implementation, or 

15 operation of a Qualified Job Training Partnership 

16 and the training financed through the investment 

17 must result in a type of certificate or credential rec18 ognized by a State accrediting body, Federal Ap19 prenticeship Agency, or any other national accred20 iting body recognized by the Department of Edu21 cation as an independent, third-party accrediting 

22 body. 

23 ‘‘(2) LIMITATION.—The amount which is treat24 ed as qualified investment for all taxable years with 

25 respect to any Qualified Job Training Partnership 


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1 shall not exceed the amount certified by the Sec2 retary as eligible for the credit under this section. 

3 ‘‘(3) EXCLUSIONS.—The qualified investment 

4 for any taxable year with respect to any Qualified 

5 Job Training Partnership shall not take into account 

6 any cost for student tuition or for any other expense 

7 as determined by the Secretary as appropriate to 

8 carry out the purposes of this section. 

9 ‘‘(4) CERTAIN PROGRESS EXPENDITURE RULES

10 MADE APPLICABLE.—In the case of costs described 

11 in paragraph (1) that are paid for property of a 

12 character subject to an allowance for depreciation, 

13 rules similar to the rules of subsections (c)(4) and 

14 (d) of section 46 (as in effect on the day before the 

15 date of the enactment of the Revenue Reconciliation 

16 Act of 1990) shall apply for purposes of this section. 

17 ‘‘(c) QUALIFIED JOB TRAINING PARTNERSHIP.— 

18 ‘‘(1) IN GENERAL.—The term ‘Qualified Job 

19 Training Partnership’ means a formal or informal 

20 partnership between at least 1 eligible private busi21 ness employer and— 

22 ‘‘(A) 1 qualified educational institution, or 

23 ‘‘(B) 1 labor organization (as defined in 

24 section 2(5) of the National Labor Relations 

25 Act), 


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1 where the stated goal of the partnership is to train 

2 students in job-ready skills. 

3 ‘‘(2) ELIGIBLE PRIVATE BUSINESS EM4 PLOYER.—The term ‘eligible private business em5 ployer’ means— 

6 ‘‘(A) a business entity at least 50 percent 

7 of the gross income of which is derived from 

8 qualified production activities (within the mean9 ing of section 199(c)), or 

10 ‘‘(B) any type of domestic business entity 

11 the average number of employees of which for 

12 any taxable year is not more than 500 employ13 ees. 

14 ‘‘(3) QUALIFIED EDUCATIONAL ORGANIZA15 TION.—The term ‘qualified educational organization’ 

16 means any educational organization described in sec17 tion 101 of the Higher Education Act of 1965 which 

18 provides a 2-year program that culminates in an as19 sociate degree. 

20 ‘‘(d) QUALIFIED JOB TRAINING PARTNERSHIP PRO21 GRAM.— 

22 ‘‘(1) ESTABLISHMENT.— 

23 ‘‘(A) IN GENERAL.—Not later than 60 

24 days after the date of the enactment of this sec25 tion, the Secretary, in consultation with the 


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1 Secretary of Labor, shall establish a Qualified 

2 Job Training Partnership program to consider 

3 and award certifications for qualified invest4 ments eligible for credits under this section to 

5 Qualified Job Training Partnerships. 

6 ‘‘(B) LIMITATION.—The total amount of 

7 credits that may be allocated under the pro8 gram shall not exceed $1,000,000,000. 

9 ‘‘(2) CERTIFICATION.— 

10 ‘‘(A) APPLICATION PERIOD.—Each appli11 cant for certification under this paragraph shall 

12 submit an application containing such informa13 tion as the Secretary may require during the 

14 period beginning on the date the Secretary es15 tablishes the program under paragraph (1). 

16 ‘‘(B) TIME FOR REVIEW OF APPLICA17 TIONS.—The Secretary shall take action to ap18 prove or deny any application under subpara19 graph (A) within 30 days of the submission of 

20 such application. 

21 ‘‘(C) MULTI-YEAR APPLICATIONS.—An ap22 plication for certification under subparagraph 

23 (A) may include a request for an allocation of 

24 credits for more than 1 year. 


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1 ‘‘(3) SELECTION CRITERIA.—In determining 

2 the Qualified Job Training Partnerships with re3 spect to which qualified investments may be certified 

4 under this section, the Secretary— 

5 ‘‘(A) shall give priority to those applica6 tions which demonstrate— 

7 ‘‘(i) the greatest probability that those 

8 who complete the program will secure em9 ployment, 

10 ‘‘(ii) the greatest potential for pro11 viding workers who complete the program 

12 with skills that can provide long-term job 

13 and income security, 

14 ‘‘(iii) the strongest market demand 

15 for the type of training offered, 

16 ‘‘(iv) the greatest probability that the 

17 program would create a net increase in job 

18 training opportunities, 

19 ‘‘(v) a strong need in the community 

20 for skills training, 

21 ‘‘(vi) the ability to allow nontradi22 tional learners to complete the training, 

23 and 


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1 ‘‘(vii) the ability and capacity to im2 plement the program in a reasonable pe3 riod of time, and 

4 ‘‘(B) shall take into additional consider5 ation which applications show— 

6 ‘‘(i) the ability to leverage additional 

7 sources of capital, and 

8 ‘‘(ii) the greatest ability to offer train9 ing programs that result in a certificate or 

10 credential (within the meaning of sub11 section (b)(1)) that is stackable or portable 

12 or both. 

13 ‘‘(4) REVIEW AND ADDITIONAL ALLOCATION.— 

14 ‘‘(A) REVIEW.—Not later than 1 year after 

15 the date of enactment of this section, the Sec16 retary shall review the credits allocated under 

17 this section as of such date. 

18 ‘‘(B) ADDITIONAL ALLOCATION.—If the 

19 Secretary determines at the time of the review 

20 that credits under this section are available for 

21 allocation pursuant to the requirements set 

22 forth in paragraph (2), the Secretary is author23 ized to allocate such available credits through 

24 the conduct of an additional program or pro25 grams for applications for certification. 


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1 ‘‘(5) DISCLOSURE OF ALLOCATIONS.—The Sec2 retary shall, upon making a certification under this 

3 subsection, publicly disclose the identity of the appli4 cant and the amount of the credit with respect to 

5 such applicant. 

6 ‘‘(e) SPECIAL RULES.— 

7 ‘‘(1) BASIS ADJUSTMENT.—For purposes of 

8 this subtitle, if a credit is allowed under this section 

9 for an expenditure related to property of a character 

10 subject to an allowance for depreciation, the basis of 

11 such property shall be reduced by the amount of 

12 such credit. 

13 ‘‘(2) DENIAL OF DOUBLE BENEFIT.— 

14 ‘‘(A) BONUS DEPRECIATION.—A credit 

15 shall not be allowed under this section for any 

16 investment for which bonus depreciation is al17 lowed under section 168(k), 1400L(b)(1), or 

18 1400N(d)(1). 

19 ‘‘(B) DEDUCTIONS.—No deduction under 

20 this subtitle shall be allowed for the portion of 

21 the expenses otherwise allowable as a deduction 

22 taken into account in determining the credit 

23 under this section for the taxable year which is 

24 equal to the amount of the credit determined 

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1 tributable to such portion. This subparagraph 

2 shall not apply to expenses related to property 

3 of a character subject to an allowance for de4 preciation the basis of which is reduced under 

5 paragraph (1), or which are described in section 

6 280C(g).’’. 

7 (b) INCLUSION AS PART OF INVESTMENT CREDIT.— 

8 Section 46 of the Internal Revenue Code of 1986 is 

9 amended— 

10 (1) by striking ‘‘and’’ at the end of paragraph 

11 (5); 

12 (2) by striking the period at the end of para13 graph (6) and inserting ‘‘, and’’; and 

14 (3) by adding at the end the following new 

15 paragraph: 

16 ‘‘(7) the Qualified Job Training Partnership 

17 credit.’’. 

18 (c) CONFORMING AMENDMENTS.— 

19 (1) Section 49(a)(1)(C) of the Internal Revenue 

20 Code of 1986 is amended— 

21 (A) by striking ‘‘and’’ at the end of clause 

22 (v); 

23 (B) by striking the period at the end of 

24 clause (vi) and inserting ‘‘, and’’; and 


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1 (C) by adding at the end the following new 

2 clause: 

3 ‘‘(vii) the basis of any property to 

4 which paragraph (1) of section 48E(e) ap5 plies which is part of a Qualified Job 

6 Training Partnership under such section 

7 48E.’’. 

8 (2) Section 280C of such Code is amended by 

9 adding at the end the following new subsection: 

10 ‘‘(j) QUALIFIED JOB TRAINING PARTNERSHIP CRED11 IT.— 

12 ‘‘(1) IN GENERAL.—No deduction shall be al13 lowed for that portion of the qualified investment (as 

14 defined in section 48E(b)) otherwise allowable as a 

15 deduction for the taxable year which is equal to the 

16 amount of the credit determined for such taxable 

17 year under section 48E(a), reduced by— 

18 ‘‘(A) the amount disallowed as a deduction 

19 by reason of section 48E(e)(2)(B), and 

20 ‘‘(B) the amount of any basis reduction 

21 under section 48E(e)(1). 

22 ‘‘(2) SIMILAR RULE WHERE TAXPAYER CAP23 ITALIZES RATHER THAN DEDUCTS EXPENSES.—In 

24 the case of expenses described in paragraph (1)(A) 


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1 taken into account in determining the credit under 

2 section 48E for the taxable year, if— 

3 ‘‘(A) the amount of the portion of the 

4 credit determined under such section with re5 spect to such expenses, exceeds 

6 ‘‘(B) the amount allowable as a deduction 

7 for such taxable year for such expenses (deter8 mined without regard to paragraph (1)), 

9 the amount chargeable to capital account for the 

10 taxable year for such expenses shall be reduced by 

11 the amount of such excess. 

12 ‘‘(3) CONTROLLED GROUPS.—Paragraph (3) of 

13 subsection (b) shall apply for purposes of this sub14 section.’’. 

15 (d) CLERICAL AMENDMENT.—The table of sections 

16 for subpart E of part IV of subchapter A of chapter 1 

17 of the Internal Revenue Code of 1986 is amended by in18 serting after the item relating to section 48D the following 

19 new item: 

‘‘Sec. 48E. Qualified Job Training Partnership credit.’’. 

20 (e) GRANTS FOR QUALIFIED INVESTMENTS IN

21 QUALIFIED JOB TRAINING PARTNERSHIPS IN LIEU OF

22 TAX CREDITS.— 

23 (1) IN GENERAL.—Upon application, the Sec24 retary of the Treasury shall, subject to the require25 ments of this subsection, provide a grant to each 


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1 person who makes a qualified investment in a Quali2 fied Job Training Partnership in an amount not to 

3 exceed 100 percent of such investment. 

4 (2) APPLICATION.— 

5 (A) IN GENERAL.—At the stated election 

6 of the applicant, an application for certification 

7 under section 48E(d)(2) of the Internal Rev8 enue Code of 1986 for a credit under such sec9 tion for any taxable year shall be considered to 

10 be an application for a grant under paragraph 

11 (1) for such taxable year. 

12 (B) SUBMISSION DATE.—An application 

13 for a grant under paragraph (1) for any taxable 

14 year shall be submitted— 

15 (i) not earlier than the day after the 

16 last day of such taxable year; and 

17 (ii) not later than the due date (in18 cluding extensions) for filing the return of 

19 tax for such taxable year. 

20 (C) INFORMATION TO BE SUBMITTED.—An 

21 application for a grant under paragraph (1) 

22 shall include such information and be in such 

23 form as the Secretary of the Treasury may re24 quire to state the amount of the credit allow25 able (but for the receipt of a grant under this 


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1 subsection) under section 48E for the taxable 

2 year for the qualified investment with respect to 

3 which such application is made. 

4 (3) TIME FOR PAYMENT OF GRANT.— 

5 (A) IN GENERAL.—The Secretary of the 

6 Treasury shall make payment of the amount of 

7 any grant under paragraph (1) during the 30- 

8 day period beginning on the later of— 

9 (i) the date of the application for such 

10 grant; or 

11 (ii) the date the qualified investment 

12 for which the grant is being made is made. 

13 (B) REGULATIONS.—In the case of invest14 ments of an ongoing nature, the Secretary of 

15 the Treasury shall issue regulations to deter16 mine the date on which a qualified investment 

17 shall be deemed to have been made for purposes 

18 of this paragraph. 

19 (4) QUALIFIED INVESTMENT.—For purposes of 

20 this subsection, the term ‘‘qualified investment’’ 

21 means a qualified investment that is certified under 

22 section 48E(d) of the Internal Revenue Code of 

23 1986 for purposes of the credit under such section 

24 48E. 

25 (5) APPLICATION OF CERTAIN RULES.— 


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1 (A) IN GENERAL.—In making grants 

2 under this subsection, the Secretary of the 

3 Treasury shall apply rules similar to the rules 

4 of section 50 of the Internal Revenue Code of 

5 1986. In applying such rules, any increase in 

6 tax under chapter 1 of such Code by reason of 

7 an investment ceasing to be a qualified invest8 ment shall be imposed on the person to whom 

9 the grant was made. 

10 (B) SPECIAL RULES.— 

11 (i) RECAPTURE OF EXCESSIVE GRANT

12 AMOUNTS.—If the amount of a grant made 

13 under this subsection exceeds the amount 

14 allowable as a grant under this subsection, 

15 such excess shall be recaptured under sub16 paragraph (A) as if the investment to 

17 which such excess portion of the grant re18 lates had ceased to be a qualified invest19 ment immediately after such grant was 

20 made. 

21 (ii) GRANT INFORMATION NOT TREAT22 ED AS RETURN INFORMATION.—In no 

23 event shall the amount of a grant made 

24 under paragraph (1), the identity of the 

25 person to whom such grant was made, or 


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1 a description of the investment with re2 spect to which such grant was made be 

3 treated as return information for purposes 

4 of section 6103 of the Internal Revenue 

5 Code of 1986. 

6 (6) SECRETARY.—Any reference in this sub7 section to the Secretary of the Treasury shall be 

8 treated as including the Secretary’s delegate. 

9 (7) OTHER TERMS.—Any term used in this sub10 section which is also used in section 48E of the In11 ternal Revenue Code of 1986 shall have the same 

12 meaning for purposes of this subsection as when 

13 used in such section. 

14 (8) DENIAL OF DOUBLE BENEFIT.—No credit 

15 shall be allowed under section 46(7) of the Internal 

16 Revenue Code of 1986 by reason of section 48E of 

17 such Code for any investment for which a grant is 

18 awarded under this subsection. 

19 (9) APPROPRIATIONS.—There is hereby appro20 priated to the Secretary of the Treasury such sums 

21 as may be necessary to carry out this subsection. 

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

23 subsections (a) through (d) of this section shall apply to 


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1 amounts paid or incurred after the date of the enactment 

2 of this Act, in taxable years beginning after such date. 

Æ 


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