(1) IN GENERAL.—Subpart A of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code 
of 1986 is amended by inserting after section 25E 
the following new section: 
‘‘SEC. 25F. QUALIFIED WORKFORCE DEVELOPMENT AND 
APPRENTICESHIP TRAINING PROGRAMS. 
‘‘(a) ALLOWANCE OF CREDIT.—In the case of an in-
dividual, there shall be allowed as a credit against the tax 
imposed by this chapter for the taxable year an amount 
equal to the amount of qualified contributions made by 
the taxpayer during the year. 
‘‘(b) DOLLAR LIMITATIONS.— 
‘‘(1) INCOME
LIMITATION.—The amount al-
lowed as a credit under subsection (a) with respect 
to any taxpayer shall not exceed 25 percent of the 
tax liability of the taxpayer with a maximum value 
of $250,000. 
‘‘(2) REDUCTION BASED ON STATE CREDIT.— 
The amount allowed as a credit under subsection (a) 
for a taxable year shall be reduced by the amount 
allowed as a credit on any State tax return of the 
individual for qualified contributions made by the 
taxpayer during the taxable year. 
‘‘(c) QUALIFIED CONTRIBUTIONS; OTHER DEFINI-
TIONS.—For purposes of this section— 
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‘‘(1) QUALIFIED
CONTRIBUTION.—The term 
‘qualified contribution’ means a charitable contribu-
tion (as defined by section 170(c)) to a workforce 
development or apprenticeship training organization. 
‘‘(2) WORKFORCE DEVELOPMENT OR APPREN-
TICESHIP
TRAINING
ORGANIZATION.—The 
term 
‘workforce development or apprenticeship training 
organization’ means any organization— 
‘‘(A) which— 
‘‘(i) is described in section 501(c)(3) 
and exempt from tax under section 501(a), 
and 
‘‘(ii) is not a private foundation, 
‘‘(B) the exclusive purpose if which is— 
‘‘(i) to provide workforce development 
and apprenticeship training to eligible par-
ticipants, including— 
‘‘(I) community colleges, 
‘‘(II) workforce training pro-
grams, as defined by State workforce 
agencies, 
‘‘(III) organizations that provide 
career and technical education, 
‘‘(IV) organizations that provide 
training or apprenticeships operated 
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by a collective bargaining organiza-
tion, 
‘‘(V) community organizations 
that provide full certified training, 
and 
‘‘(VI) private schools that confer 
diplomas, degrees, or certify comple-
tion of certain grades, or 
‘‘(ii) to provide scholarships for use in 
obtaining workforce development and ap-
prenticeship training described in clause (i) 
at an organization which is exempt from 
tax under section 501(a) (other than a pri-
vate foundation), and 
‘‘(C) that is in compliance with all applica-
ble State laws, including laws relating to unlaw-
ful discrimination, health and safety require-
ments, and criminal background checks of em-
ployees. 
‘‘(3) ELIGIBLE PARTICIPANTS.—The term ‘eli-
gible participant’ means an individual who is en-
rolled in a workforce development and apprentice-
ship training organization, as described in paragraph 
(2)(B). 
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‘‘(d) DENIAL OF DOUBLE BENEFIT.—No deduction 
shall be allowed under any provision of this chapter for 
any expense for which a credit is allowed under this sec-
tion. 
‘‘(e) ELECTION.—This section shall apply to a tax-
payer for a taxable year only if such taxpayer elects to 
have this section apply for such taxable year. 
‘‘(f) APPLICATION OF VOLUME CAP.—A contribution 
shall be taken into account under this section only if such 
contribution is recognized by the Secretary as applying 
against the volume cap established under section 4 of the 
USA Workforce Tax Credit Act.’’. 
(2) CLERICAL AMENDMENT.—The table of sec-
tions for subpart A of part IV of subchapter A of 
chapter 1 of such Code is amended by inserting 
after the item relating to section 25E the following 
new item: 
‘‘Sec. 25F. Qualified Workforce Development and Apprenticeship Training Pro-
grams.’’. 
(b) BUSINESS CREDIT.— 
(1) IN GENERAL.—Subpart D of part IV of 
subchapter A of chapter 1 of such Code is amended 
by adding at the end the following new section: 
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‘‘SEC. 45BB. CONTRIBUTIONS TO WORKFORCE DEVELOP-
MENT OR APPRENTICESHIP TRAINING ORGA-
NIZATIONS. 
‘‘(a) GENERAL RULE.—For purposes of section 38, 
in the case of a corporation, the workforce development 
and apprenticeship training credit determined under this 
section for the taxable year is the aggregate amount of 
qualified contributions for the taxable year. 
‘‘(b) LIMITATION.— 
‘‘(1) INCOME LIMITATION.—The amount of the 
credit determined under this section for any taxable 
year shall not exceed the lesser of— 
‘‘(A) 25 percent of the tax liability of the 
taxpayer for the taxable year, and 
‘‘(B) $250,000. 
‘‘(2) REDUCTION BASED ON STATE CREDIT.— 
The amount allowed as a credit under subsection (a) 
for a taxable year shall be reduced by the amount 
allowed as a credit on any State tax return of the 
individual for qualified contributions made by the 
taxpayer during the taxable year. 
‘‘(3) QUALIFIED
CONTRIBUTIONS.—For pur-
poses of this section, the term ‘qualified contribu-
tion’ has the meaning given such term under section 
25F. 
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‘‘(c) DENIAL OF DOUBLE BENEFIT.—No deduction 
shall be allowed under any provision of this chapter for 
any expense for which a credit is allowed under this sec-
tion. 
‘‘(d) ELECTION.—This section shall apply to a tax-
payer for a taxable year only if such taxpayer elects to 
have this section apply for such taxable year. 
‘‘(e) APPLICATION OF VOLUME CAP.—A contribution 
shall be taken into account under this section only if such 
contribution is recognized by the Secretary as applying 
against the volume cap established under section 4 of the 
USA Workforce Tax Credit Act.’’. 
(2) 
CONFORMING
AMENDMENTS.—Section 
38(b) of such Code is amended by striking ‘‘plus’’ at 
the end of paragraph (40), by striking the period 
and inserting ‘‘, plus’’ at the end of paragraph (41), 
and by adding at the end the following new para-
graph: 
‘‘(42) the workforce development or apprentice-
ship training credit determined under section 
45BB(a).’’. 
(3) CLERICAL AMENDMENT.—The table of sec-
tions for subpart D of part IV of subchapter A of 
chapter 1 of such Code is amended by adding at the 
end the following new item: 
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‘‘Sec. 45BB. Contributions to workforce development or apprenticeship training 
organizations.’’. 
(c) EXCISE TAX
ON FAILURE
OF SCHOLARSHIP 
GRANTING ORGANIZATIONS TO MAKE DISTRIBUTIONS.— 
(1) IN GENERAL.—Chapter 42 of such Code is 
amended by adding at the end the following new 
subchapter: 
‘‘Subchapter 
I—Organizations 
Providing 
Workforce Development or Apprentice-
ship Training 
‘‘Sec. 4969. Tax on failure to distribute receipts. 
‘‘SEC. 4969. TAX ON FAILURE TO DISTRIBUTE RECEIPTS. 
‘‘(a) TAX IMPOSED.—There is hereby imposed a tax 
on the failure of a workforce development or apprentice-
ship training organization (as defined in section 25F(c)) 
to make distributions in any taxable year in an amount 
equal to or in excess of the required distribution amount 
before the distribution deadline relating to a taxable year. 
‘‘(b) AMOUNT OF TAX.—The tax imposed by sub-
section (a) with respect to a taxable year shall be equal 
to 15 percent of the excess (if any) of— 
‘‘(1) the required distribution amount with re-
spect to the taxable year, over 
‘‘(2) the amount of receipts of the workforce de-
velopment or apprenticeship training organization 
for each taxable year which are distributed before 
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the distribution deadline with respect to such re-
ceipts. 
‘‘(c) DEFINITIONS.—For purposes of this section— 
‘‘(1) REQUIRED DISTRIBUTION AMOUNT.— 
‘‘(A) IN GENERAL.—The required distribu-
tion amount with respect to a taxable year is 
the amount equal to 100 percent of the total re-
ceipts of the workforce development or appren-
ticeship training organization for such taxable 
year— 
‘‘(i) reduced by the sum of such re-
ceipts that are retained for administrative 
expenses for the taxable year or are carried 
to the succeeding taxable year under sub-
paragraph (C), and 
‘‘(ii) increased by the amount of the 
carryover under subparagraph (C) from 
the preceding taxable year. 
‘‘(B) ADMINISTRATIVE
EXPENSES.—For 
purposes of this paragraph, not more than 10 
percent of total receipts of a qualified workforce 
development or apprenticeship training organi-
zation for a taxable year may be used for ad-
ministrative purposes. 
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‘‘(C) CARRYOVER.—Receipts of a qualified 
workforce development or apprenticeship train-
ing organization that are not disbursed for the 
taxable year or retained for administrative pur-
poses for the taxable year shall be carried to 
the succeeding taxable year. The amount car-
ried to the taxable year under the preceding 
sentence shall not exceed 15 percent of total re-
ceipts of the qualified workforce development or 
apprenticeship training organization for the 
taxable year. 
‘‘(2) DISTRIBUTIONS.—The term ‘distribution’ 
includes amounts which are formally committed but 
not distributed. A formal commitment described in 
the preceding sentence may include contributions set 
aside for eligible students or participants for more 
than one year. 
‘‘(3) DISTRIBUTION DEADLINE.—The distribu-
tion deadline with respect to receipts for a taxable 
year is the first day of the second taxable year fol-
lowing the taxable year in which such receipts are 
received by the scholarship granting organization. 
‘‘(d) REASONABLE CAUSE EXCEPTION.—The tax im-
posed by subsection (a) shall not apply with respect to any 
failure to make required distributions before the distribu-
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tion deadline which is not willful and is due to reasonable 
cause.’’. 
(2) ABATEMENT OF TAX.— 
(A) GENERAL
RULE.—Subsection (b) of 
section 4962 of such Code is amended by strik-
ing ‘‘or G’’ and inserting ‘‘G, or I’’. 
(B) FIRST TIER TAX.—Subsection (a) of 
section 4963 of such Code is amended by in-
serting ‘‘4969,’’ after ‘‘4967,’’. 
(C) TAXABLE EVENT.—Subsection (c) of 
section 4963 of such Code is amended by in-
serting ‘‘4969,’’ after ‘‘4967,’’. 
(3) CORRECTION PERIOD.—Subparagraph (A) 
of section 4963(e)(2) of such Code is amended by in-
serting ‘‘or 4969’’ after ‘‘4942’’. 
(4) CLERICAL AMENDMENT.—The table of sub-
chapters for chapter 42 of such Code is amended by 
adding at the end the following new item: 
‘‘SUBCHAPTER I. ORGANIZATIONS PROVIDING WORKFORCE DEVELOPMENT, 
APPRENTICESHIP TRAINING, OR SCHOLARSHIPS’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this Act shall apply to taxable years beginning after De-
cember 31, 2023. 
SEC. 3. ORGANIZATIONAL AUTONOMY. 
A participating eligible organization or entity under 
the programs established pursuant to this Act are autono-
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mous and not agents of the State or Federal Government 
and therefore— 
(1) a Federal or State agency may not in any 
way regulate the program of a participating entity 
that accepts a contribution under this Act; 
(2) the provision of tax credits under this Act 
does not expand the regulatory authority of the Fed-
eral Government, the State, its officers, or any 
school district to impose any additional regulation of 
an entity beyond those necessary to enforce the re-
quirements of this Act; and 
(3) participating eligible entities shall be given 
the maximum freedom to provide for the needs of 
their participants without government control. 
SEC. 4. VOLUME CAP. 
(a) AMOUNT.—The volume cap amount available for 
tax credits allowed under sections 25F and 45BB of the 
Internal Revenue Code of 1986, as added by this Act, shall 
be $2,000,000,000 annually, beginning for taxable years 
beginning in 2024 and for each succeeding calendar year 
thereafter. 
(b) APPLICATION
FOR
CREDITS.—The Secretary 
shall develop a system to track and make available infor-
mation in real time, regarding availability of such tax 
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credits to donors which will be available on a first-come, 
first-serve basis. 
Æ 
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