I 
119TH CONGRESS 
1ST SESSION H. R. 2410 
To amend the Internal Revenue Code of 1986 to provide an investment 
credit for converting non-residential buildings to affordable housing. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 27, 2025 
Mr. CAREY (for himself, Mr. GOMEZ, Mr. LARSON of Connecticut, Mr. 
FITZPATRICK, Ms. SEWELL, Ms. TENNEY, Mr. BEYER, Mr. KUSTOFF, 
Ms. CHU, Mr. KELLY of Pennsylvania, Mr. PANETTA, Mrs. MILLER of 
West Virginia, Mr. DAVIS of Illinois, Mr. MOORE of Utah, Mr. EVANS 
of Pennsylvania, Ms. MALLIOTAKIS, Mr. SUOZZI, Mr. MORAN, Mr. BOYLE 
of Pennsylvania, Mr. LAHOOD, Ms. SA´NCHEZ, Mr. MILLER of Ohio, Ms. 
MOORE of Wisconsin, Mr. AMODEI of Nevada, Mr. SCHNEIDER, Mr. 
CISCOMANI, Mr. HORSFORD, and Ms. DELBENE) 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 provide 
an investment credit for converting non-residential build-
ings to affordable housing. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Revitalizing Down-
towns and Main Streets Act’’. 
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SEC. 2. INVESTMENT CREDIT FOR CONVERSION OF NON- 
RESIDENTIAL BUILDINGS TO AFFORDABLE 
HOUSING. 
(a) IN GENERAL.—Subpart E of part IV of sub-
chapter A of chapter 1 of subtitle A of the Internal Rev-
enue Code of 1986 is amended by inserting after section 
48E the following new section: 
‘‘SEC. 48F. AFFORDABLE HOUSING CONVERSION CREDIT. 
‘‘(a) ALLOWANCE OF CREDIT.—For purposes of sec-
tion 46, the affordable housing conversion credit for any 
taxable year is an amount equal to 20 percent of the quali-
fied conversion expenditures of the taxpayer with respect 
to a qualified affordable housing building placed in service 
by the taxpayer during the taxable year. 
‘‘(b) QUALIFIED CONVERSION EXPENDITURES.—For 
purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘qualified conver-
sion expenditures’ means, with respect to any quali-
fied affordable housing building, any amount prop-
erly chargeable to capital account— 
‘‘(A) for property for which depreciation is 
allowable under section 168, and 
‘‘(B) in connection with the qualified con-
version of a qualified affordable housing build-
ing. 
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‘‘(2) 
CERTAIN
EXPENDITURES
NOT
IN-
CLUDED.—The term ‘qualified conversion expendi-
tures’ does not include— 
‘‘(A) LIMITATION ON PERIOD OF CONVER-
SION.—Except as provided in subsection (f), 
any amount paid or incurred other than during 
the 2-year period ending on the date on which 
the taxpayer places the qualified affordable 
housing building in service. 
‘‘(B) COST OF ACQUISITION.—The cost of 
acquiring any building or interest therein. 
‘‘(3) SPECIAL
RULE
FOR
BROWNFIELDS.— 
Paragraph (1)(A) shall not apply with respect to any 
expenditure for clean up of qualifying brownfield 
property (as defined in section 512(b)(19)). 
‘‘(4) COORDINATION
WITH
REHABILITATION 
CREDIT.—In the case of any qualified conversion ex-
penditures which are taken into account for pur-
poses of determining the rehabilitation credit under 
section 47, the amount of such expenditures taken 
into account under this section (determined without 
regard to this paragraph) shall be reduced by 50 
percent. 
‘‘(c) QUALIFIED CONVERSION.—For purposes of this 
section— 
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‘‘(1) IN GENERAL.—The term ‘qualified conver-
sion’ means the conversion of an eligible commercial 
building into a qualified affordable housing building 
if the qualified conversion expenditures of the tax-
payer with respect to such conversion exceed the 
greater of— 
‘‘(A) an amount equal to 50 percent of the 
adjusted basis of such building (determined im-
mediately prior to such conversion), or 
‘‘(B) $100,000. 
‘‘(2) ELIGIBLE
COMMERCIAL
BUILDING.—The 
term ‘eligible commercial building’ means any build-
ing which, with respect to any conversion— 
‘‘(A) was originally placed in service not 
less than 20 years before the date on which 
such conversion begins, and 
‘‘(B) immediately prior to such conversion, 
was nonresidential real property (as defined in 
section 168). 
‘‘(d) QUALIFIED AFFORDABLE HOUSING BUILD-
ING.—For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘qualified afford-
able housing building’ means any residential building 
if during the 30-year period beginning on the date 
on which such building is placed in service by the 
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taxpayer, not less than 20 percent of the residential 
units in the building are both rent-restricted and re-
served for individuals whose income is 80 percent or 
less of the area median income. 
‘‘(2) RENT
AND
INCOME
LIMITATION.—For 
purposes of this subsection, rules similar to the rules 
of subsection (g) of section 42 shall apply to deter-
mine whether a unit is rent-restricted, treatment of 
units occupied by individuals whose incomes rise 
above the limit, and the treatment of units where 
Federal rental assistance is reduced as tenant’s in-
come increases. 
‘‘(e) LIMITATION ON AGGREGATE CREDIT ALLOW-
ABLE.— 
‘‘(1) CREDIT
MAY
NOT
EXCEED
CREDIT 
AMOUNT ALLOCATED TO BUILDING.— 
‘‘(A) IN
GENERAL.—The amount of the 
credit determined under this section with re-
spect to any building shall not exceed the quali-
fied conversion credit dollar amount allocated to 
such building under this subsection by the 
housing credit agency of the State in which 
such building is located. 
‘‘(B) TIME
FOR
MAKING
ALLOCATION.— 
Except in the case of an allocation which meets 
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‘‘(ii) the sum of any amounts deter-
mined under subparagraph (C). 
‘‘(B) NATIONAL
QUALIFIED
CONVERSION 
CREDIT
LIMITATION.—The national qualified 
conversion credit limitation is $12,000,000,000. 
‘‘(C) ADDITIONAL
AMOUNTS
PROVIDED 
FOR
CERTAIN
BUILDINGS
IN
ECONOMICALLY 
DISTRESSED AREAS.— 
‘‘(i) IN
GENERAL.—For purposes of 
subparagraph (A)(ii), in any case in 
which— 
‘‘(I) the housing credit agency of 
a State allocates an amount to a 
building which is located in an eco-
nomically distressed area, and 
‘‘(II) the Secretary subsequently 
designates such amount for purposes 
of this paragraph, 
the amount determined under this para-
graph with respect to such building shall 
be the amount originally allocated by the 
housing credit agency of the State under 
clause (i). 
‘‘(ii) 
LIMITATION.—The 
aggregate 
amount which the Secretary may designate 
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under clause (i)(II) shall not exceed 
$3,000,000,000. 
‘‘(iii) MANNER
OF
DESIGNATION.— 
Not later than 120 days after the date of 
the enactment of this section, the Sec-
retary shall establish a program for deter-
mining the designation of amounts that 
may be designated under this subpara-
graph. 
‘‘(D) 
REALLOCATION
OF
CERTAIN 
AMOUNTS.— 
‘‘(i) IN
GENERAL.—Notwithstanding 
subparagraph (A)— 
‘‘(I) no amount may be allocated 
under paragraph (1) by a housing 
credit agency of an undersubscribed 
State after December 31, 2028, and 
‘‘(II) the dollar amount deter-
mined under subparagraph (A) with 
respect to any oversubscribed State 
after such date shall be increased by 
such State’s share of the reallocation 
amount. 
‘‘(ii) STATE SHARE.—For purposes of 
clause (i), an oversubscribed State’s share 
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of the reallocation amount is the amount 
which bears the same ratio to the realloca-
tion amount as— 
‘‘(I) the population of such State, 
bears to 
‘‘(II) the population of all over-
subscribed States. 
‘‘(iii) DEFINITIONS.—For purposes of 
this subparagraph— 
‘‘(I) 
UNDERSUBSCRIBED 
STATE.—The term ‘undersubscribed 
State’ means any State that is not an 
oversubscribed State. 
‘‘(II) 
OVERSUBSCRIBED 
STATE.—The 
term 
‘oversubscribed 
State’ means any State the housing 
credit agency of which has allocated 
all of the qualified conversion credit 
dollar amount which may be allocated 
by it before the date described in 
clause (i)(I). 
‘‘(III) 
REALLOCATION 
AMOUNT.—The 
term 
‘reallocation 
amount’ means the sum of the 
amounts described in subparagraph 
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(A) which have not been allocated by 
undersubscribed States before the 
date described in clause (i)(I). 
‘‘(3) MANNER OF ALLOCATION.— 
‘‘(A) PLAN FOR ALLOCATION.— 
‘‘(i) IN
GENERAL.—Notwithstanding 
any other provision of this section, the 
qualified conversion credit dollar amount 
with respect to any building shall be zero 
unless such amount was allocated pursuant 
to a conversion credit allocation plan of the 
housing credit agency which is approved by 
the governmental unit (in accordance with 
rules similar to the rules of section 
147(f)(2) (other than subparagraph (B)(ii) 
thereof)) of which such agency is a part. 
‘‘(ii) CONVERSION
CREDIT
ALLOCA-
TION
PLAN.—For purposes of this sub-
paragraph, the term ‘conversion credit allo-
cation plan’ means a plan— 
‘‘(I) which sets selection criteria 
for allocations, taking into account— 
‘‘(aa) whether the credit is 
needed to assure the financial 
feasibility of the conversion, 
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‘‘(bb) the extent to which 
the conversion results in the cre-
ation of affordable housing, 
‘‘(cc) the extent to which the 
conversion results in the creation 
of housing near transportation, 
employment, and commercial op-
portunities, 
‘‘(dd) the extent to which 
the conversion will support small 
businesses and economic revital-
ization in the surrounding area, 
‘‘(ee) the degree of local gov-
ernment support for the conver-
sion, and 
‘‘(ff) the readiness of the 
building for a qualified conver-
sion, and 
‘‘(II) which provides a procedure 
that the agency (or an agent or other 
private contractor of such agency) will 
follow in monitoring for noncompli-
ance with the requirements of sub-
section (d) and in notifying the Inter-
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nal Revenue Service of such non-
compliance. 
‘‘(B) BINDING ALLOCATION AGREEMENTS; 
REPORTING.—In making allocations of qualified 
conversion credit dollar amounts, each housing 
credit agency shall— 
‘‘(i) enter into binding agreements 
with taxpayers for the allocation of quali-
fied conversion credit dollar amounts, 
which agreements shall specify the amount 
of qualified conversion credit dollar amount 
allocated to the building and the terms for 
any modifications or withdrawal of such al-
location, and 
‘‘(ii) report to the Secretary, at such 
time and in such manner as the Secretary 
may require, the amount of allocations 
made with respect to any building. 
‘‘(C) STATE
EXTENDED
USE
REQUIRE-
MENTS PERMITTED PAST 30 YEARS.—For pur-
poses of this paragraph, a housing credit agen-
cy’s plan shall not fail to be treated as a con-
version credit allocation plan merely because it 
includes, and nothing in this section shall be 
construed to limit a binding allocation agree-
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ment from including, affordability or rent re-
striction requirements with respect to the build-
ing that apply for a longer period than the 30- 
year period described in subsections (d) and 
(g)(1)(B). 
‘‘(4) DEFINITIONS AND OTHER RULES.— 
‘‘(A) HOUSING
CREDIT
AGENCY.—The 
term ‘housing credit agency’ means, with re-
spect to any State, the housing credit agency 
authorized under section 42(h)(8) or such other 
agency as authorized by the State for purposes 
of this section. 
‘‘(B) ECONOMICALLY DISTRESSED AREA.— 
The term ‘economically distressed area’ means 
any area which— 
‘‘(i) has been designated as a qualified 
census tract under section 42(d)(5)(B)(ii) 
or as a difficult development area under 
section 42(d)(5)(B)(iii), or 
‘‘(ii) meets the requirement of section 
301(a)(3) of the Public Works and Eco-
nomic Development Act of 1965. 
‘‘(C) STATE.—The term ‘State’ includes a 
possession of the United States. 
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‘‘(D) OTHER RULES.—Rules similar to the 
rules of subparagraphs (A) and (B) of section 
42(h)(7) shall apply for purposes of this sec-
tion. 
‘‘(f) PROGRESS EXPENDITURES.—If the Secretary 
determines, on the basis of architectural plans and speci-
fications that a qualified conversion is reasonably expected 
to exceed 2 years, rules similar to the rules of section 
47(d) shall apply with respect to such conversion for pur-
poses of this section. 
‘‘(g) SPECIAL RULES FOR CERTAIN AREAS.— 
‘‘(1) QUALIFIED
CENSUS
TRACTS
AND
DIF-
FICULT
DEVELOPMENT
AREAS.—In the case of a 
qualified affordable housing building— 
‘‘(A) which is located in any area which is 
designated as a qualified census tract under 
section 42(d)(5)(B)(ii) or as a difficult develop-
ment area under section 42(d)(5)(B)(iii)), and 
‘‘(B) with respect to which during 30-year 
period beginning on the date on which such 
building is placed in service by the taxpayer, 
not less than 20 percent of the residential units 
in the building are both rent-restricted and re-
served for individuals whose income is 60 per-
cent or less of the area median income, 
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subsection (a) shall be applied by substituting ‘30 
percent’ for ‘20 percent’. 
‘‘(2) 
HISTORIC
PRESERVATION
IN
RURAL 
AREAS.— 
‘‘(A) IN GENERAL.—In the case of a quali-
fied affordable housing building which is in a 
rural area and is part of an historic preserva-
tion project, the taxpayer may elect to sub-
stitute ‘35 percent’ for ‘20 percent’ under sub-
section (a) with respect to such portion of the 
aggregate qualified conversion expenditures 
taken into account under such subsection as 
does not exceed $2,000,000. 
‘‘(B) DEFINITIONS.—For purposes of this 
paragraph— 
‘‘(i) RURAL AREA.—The term ‘rural 
area’ shall have the meaning given such 
term under section 1393(a)(2). 
‘‘(ii) 
HISTORIC
PRESERVATION 
PROJECT.—The term ‘historic preservation 
project’ means a qualified conversion which 
involves the certified rehabilitation of a 
certified historic structure. Whether con-
version of a certified historic structure in-
volves certified rehabilitation shall be de-
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termined under rules similar to the rules of 
section 47(c)(2)(C). 
‘‘(h) REGULATIONS.—The Secretary shall issue such 
regulations or other guidance as may be necessary or ap-
propriate to carry out the purposes of this section, includ-
ing regulations or other guidance— 
‘‘(1) providing for the recapture of the credit 
determined under subsection (a) if the qualified af-
fordable housing building ceases to be a qualified af-
fordable housing building during the 30-year period 
beginning on the date that such building is placed 
in service by the taxpayer, 
‘‘(2) detailing any certifications required from 
the taxpayer or any housing credit agency of a 
State, 
‘‘(3) with respect to the application of sub-
section (b)(4), 
‘‘(4) with respect to information reporting on 
allocations of qualified conversion credit dollar 
amounts, 
‘‘(5) providing rules for making a determination 
as to whether an area is described in subsection 
(e)(4)(B), and 
‘‘(6) which encourages housing credit agencies 
to allocate, to the extent practicable, qualified con-
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version credit dollar amounts to non-metropolitan 
counties within a State in proportion to the non- 
metropolitan population of the State, but only to the 
extent it is demonstrated within such non-metropoli-
tan counties that there are sufficient qualified con-
version expenditures to warrant such allocations.’’. 
(b) 
TRANSFERABILITY
OF
CREDIT.—Section 
6418(f)(1)(A) of such Code is amended by adding at the 
end the following new clause: 
‘‘(xii) The affordable housing conver-
sion 
credit 
determined 
under 
section 
48F.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 46 of such Code is amended in 
paragraph (5) by striking ‘‘and’’ at the end, in para-
graph (6) by striking the period at the end and in-
serting ‘‘, and’’, and by adding at the end the fol-
lowing new paragraph: 
‘‘(7) the affordable housing conversion credit.’’. 
(2) Section 49(a)(1)(C) of such Code is amend-
ed by striking ‘‘and’’ at the end of clause (v), in 
clause (vi) by striking the period at the end and in-
serting ‘‘, and’’, and by adding at the end the follow 
new clause: 
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‘‘(vii) the basis of any property which 
is being converted as part of a qualified 
conversion under section 48F.’’. 
(3) Section 50(a)(2)(E) of such Code is amend-
ed by striking ‘‘or 48E(e)’’ and inserting ‘‘48E(e), 
or 48F(f)’’. 
(4) The table of sections for subpart E of part 
IV of subchapter A of chapter 1 of subtitle A of 
such Code is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 48F. Affordable housing conversion credit.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to qualified affordable housing 
buildings (as defined in section 48F of the Internal Rev-
enue Code of 1986, as added by this section) placed in 
service after the date of the enactment of this Act. 
Æ 
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