SEC. 10. FEDERAL INFRASTRUCTURE BANK HOLDING COM-
PANY CREDIT. 
(a) IN GENERAL.—Subpart D of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended— 
(1) by adding at the end the following new sec-
tion: 
‘‘SEC. 45AA. FEDERAL INFRASTRUCTURE BANK HOLDING 
COMPANY CREDIT. 
‘‘(a) IN GENERAL.—For purposes of section 38, in 
the case of a taxpayer who holds a qualified Holding Com-
pany equity investment on a credit allowance date of such 
investment which occurs during the taxable year, the Fed-
eral Infrastructure Bank Holding Company credit deter-
mined under this section for such taxable year is an 
amount equal to 10 percent of the amount paid to the 
Holding Company for such investment at its original issue. 
‘‘(b) CREDIT ALLOWANCE DATE.—For purposes of 
this section, the credit allowance date with respect to any 
qualified Holding Company equity investment is— 
‘‘(1) the date on which such investment is ini-
tially made; and 
‘‘(2) each of the 4 taxable years thereafter. 
‘‘(c) QUALIFIED HOLDING COMPANY EQUITY IN-
VESTMENT.—For purposes of this section, the term ‘quali-
fied Holding Company equity investment’ means any eq-
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uity investment originally issued by the Holding Company 
to the taxpayer under section 6(a)(1) of the Federal Infra-
structure Bank Act of 2023 not later than 3 years after 
the formation of the Federal Infrastructure Bank Holding 
Company pursuant to section 3 of the Federal Infrastruc-
ture Bank Act of 2023. 
‘‘(d) HOLDING COMPANY.—For purposes of this sec-
tion, the term ‘Holding Company’ means the Federal In-
frastructure Bank Holding Company established by the 
Federal Infrastructure Bank Act of 2023.’’; and 
(2) in the table of contents for such subpart, by 
adding at the end the following: 
‘‘45AA. Federal Infrastructure Bank Holding Company credit.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 38(b) of such Code is amended by 
striking ‘‘plus’’ at the end of paragraph (37), by 
striking the period at the end of paragraph (38) and 
inserting ‘‘, plus’’, and by adding at the end the fol-
lowing new paragraph: 
‘‘(39) the Federal Infrastructure Bank Holding 
Company credit determined under section 45AA.’’. 
(2) Section 1016(a) of such Code is amended 
by striking ‘‘and’’ at the end of paragraph (37), by 
striking the period at the end of paragraph (38) and 
inserting ‘‘, and’’, and by adding at the end the fol-
lowing new paragraph: 
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‘‘(39) to the extent provided in section 
45AA(e).’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
SEC. 11. RULE OF CONSTRUCTION. 
Nothing in this Act may be construed as authorizing 
the Federal Government to guarantee the assets of the 
Bank or Holding Company. 
Æ 
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