I 
119TH CONGRESS 
1ST SESSION H. R. 2941 
To amend the Internal Revenue Code of 1986 to improve the historic 
rehabilitation tax credit, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 17, 2025 
Mr. LAHOOD (for himself and Mr. SUOZZI) 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 improve 
the historic rehabilitation tax credit, and for other purposes. 
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 ‘‘Historic Tax Credit 
Growth and Opportunity Act of 2025’’. 
SEC. 2. FULL CREDIT ALLOWED IN THE YEAR BUILDING 
PLACED IN SERVICE. 
(a) IN GENERAL.—Section 47(a) of the Internal Rev-
enue Code of 1986 is amended to read as follows: 
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‘‘(a) GENERAL RULE.—For purposes of section 46, 
the rehabilitation credit for any taxable year is 20 percent 
of the qualified rehabilitation expenditures.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to property placed in service after 
December 31, 2023. 
SEC. 3. INCREASE IN THE REHABILITATION CREDIT FOR 
CERTAIN SMALL PROJECTS. 
(a) IN GENERAL.—Section 47 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(e) SPECIAL RULE REGARDING CERTAIN SMALL 
PROJECTS.— 
‘‘(1) IN GENERAL.—In the case of any quali-
fying small project with respect to which there is an 
election in effect under this subsection— 
‘‘(A) the total qualified rehabilitation ex-
penditures taken into account for purposes of 
this section with respect to the rehabilitation 
shall not exceed $3,750,000, 
‘‘(B) subsection (a) shall be applied by 
substituting ‘30 percent’ for ‘20 percent’, and 
‘‘(C) subject to paragraph (4) and such 
regulations or other guidance as the Secretary 
may provide, the taxpayer may transfer all or 
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a portion of the credit determined under this 
section with respect to such qualifying small 
project. 
‘‘(2) QUALIFYING SMALL PROJECT.—For pur-
poses of this subsection, the term ‘qualifying small 
project’ means any qualified rehabilitated building or 
portion thereof if— 
‘‘(A) such building is placed in service 
after the date of the enactment of this sub-
section, and 
‘‘(B) no credit was allowed under this sec-
tion (other than a credits allowed by reason of 
subsection (d)) for either of the two imme-
diately preceding taxable years with respect to 
such building. 
‘‘(3) SPECIAL RULE FOR RURAL PROJECTS.— 
‘‘(A) IN
GENERAL.—In the case of any 
qualifying small project in a rural area, para-
graph (1)(A) shall be applied by substituting 
‘$5,000,000’ for ‘$3,750,000’. 
‘‘(B) RURAL AREA.—For purposes of this 
subparagraph, the term ‘rural area’ means any 
area other than— 
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‘‘(i) a city or town that has a popu-
lation of greater than 50,000 inhabitants, 
or 
‘‘(ii) the urbanized area contiguous 
and adjacent to a city or town described in 
clause (i), as defined by the Bureau of the 
Census based on the latest decennial cen-
sus of the United States. 
‘‘(4) TRANSFER OF CREDIT FOR QUALIFYING 
SMALL PROJECTS.— 
‘‘(A) CERTIFICATION.— 
‘‘(i) IN GENERAL.—A transfer under 
paragraph (1)(C) shall be accompanied by 
a certificate which includes— 
‘‘(I) the certification for the cer-
tified historic structure referred to in 
subsection (c)(3), 
‘‘(II) the taxpayer’s name, ad-
dress, tax identification number, date 
of project completion, and the amount 
of credit being transferred, 
‘‘(III) the transferee’s name, ad-
dress, tax identification number, and 
the amount of credit being trans-
ferred, and 
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‘‘(IV) such other information as 
may be required by the Secretary. 
‘‘(ii) TRANSFERABILITY OF CERTIFI-
CATE.—A certificate issued under this sub-
section to a taxpayer shall be transferable 
to any other taxpayer. 
‘‘(B) TAX TREATMENT RELATING TO CER-
TIFICATE.— 
‘‘(i) 
DISALLOWANCE
OF
DEDUC-
TION.—No deduction shall be allowed for 
the amount of consideration paid or in-
curred by the transferee. 
‘‘(ii) ALLOWANCE
OF
CREDIT.—The 
amount of credit transferred under para-
graph (1)(C)— 
‘‘(I) shall not be allowed to the 
transferor for any taxable year, and 
‘‘(II) shall be allowable to the 
transferee as a credit determined 
under this section for the taxable year 
of the transferee in which such credit 
is transferred. 
‘‘(iii) 
EXCLUSION.—Gross 
income 
shall not include any amount received in 
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connection with the transfer of the certifi-
cate. 
‘‘(C) RECAPTURE
AND
OTHER
SPECIAL 
RULES.—The taxpayer who claims a credit de-
termined under this section by reason of a 
transfer of an amount of credit under para-
graph (1)(A) with respect to an applicable rural 
project shall be treated as the taxpayer with re-
spect to such project for purposes of section 50. 
‘‘(D) 
INFORMATION
REPORTING.—The 
transferor and the transferee shall each make 
such reports regarding the transfer of an 
amount of credit under paragraph (1)(C) and 
containing such information as the Secretary 
may require. The reports required by this sub-
paragraph shall be filed at such time and in 
such manner as may be required by the Sec-
retary. 
‘‘(E) REGULATIONS.—The Secretary shall 
prescribe regulations or other guidance to carry 
out paragraph (1)(C) and this paragraph in a 
manner which is consistent with applicable re-
quirements with respect to transfer of credits 
under section 6418. 
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‘‘(5) ELECTION.—An election under this sub-
section shall be made at such time and in such man-
ner as the Secretary may by regulations prescribe.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to property placed in service after 
the date of the enactment of this Act. 
SEC. 4. INCREASING THE TYPE OF BUILDINGS ELIGIBLE 
FOR REHABILITATION. 
(a) IN GENERAL.—Section 47(c)(1)(B)(i)(I) of the 
Internal Revenue Code of 1986 is amended by inserting 
‘‘50 percent of’’ before ‘‘the adjusted basis’’. 
(b) EFFECTIVE DATE.—The amendment made by 
subsection (a) shall apply to property placed in service 
after the date of the enactment of this Act. 
SEC. 5. ELIMINATION OF REHABILITATION CREDIT BASIS 
ADJUSTMENT. 
(a) IN GENERAL.—Section 50(c) of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new paragraph: 
‘‘(6) EXCEPTION FOR REHABILITATION CRED-
IT.—In the case of the rehabilitation credit, para-
graph (1) shall not apply.’’. 
(b) TREATMENT IN CASE OF CREDIT ALLOWED TO 
LESSEE.—Section 50(d) of such Code is amended by add-
ing at the end the following: ‘‘In the case of the rehabilita-
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tion credit, paragraph (5)(B) of the section 48(d) referred 
to in paragraph (5) of this subsection shall not apply.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service after 
the date of the enactment of this Act. 
SEC. 6. MODIFICATIONS REGARDING CERTAIN TAX-EXEMPT 
USE PROPERTY. 
(a) IN GENERAL.—Section 47(c)(2)(B)(v) of the In-
ternal Revenue Code of 1986 is amended by adding at the 
end the following new subclause: 
‘‘(III) 
DISQUALIFIED
LEASE 
RULES TO APPLY ONLY IN CASE OF 
GOVERNMENT ENTITY.—For purposes 
of subclause (I), except in the case of 
a tax-exempt entity described in sec-
tion 168(h)(2)(A)(i), the determina-
tion of whether property is tax-exempt 
use property shall be made under sec-
tion 168(h) without regard to whether 
the property is leased in a disqualified 
lease 
(as 
defined 
in 
section 
168(h)(1)(B)(ii)).’’. 
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(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service after 
the date of the enactment of this Act. 
Æ 
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