I 
119TH CONGRESS 
2D SESSION 
H. R. 7450 
To amend the Internal Revenue Code of 1986 to allow a portion of general 
business credit carryforwards to be transferred by certain taxpayers 
affected by federally declared disasters and other incidents. 
IN THE HOUSE OF REPRESENTATIVES 
FEBRUARY 9, 2026 
Mr. STEUBE (for himself, Mr. MURPHY, Mr. BUCHANAN, Ms. DELBENE, Ms. 
SEWELL, Mr. HUDSON, Mr. EDWARDS, Mr. SOTO, Mr. MOSKOWITZ, and 
Mr. HARRIGAN) 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 allow a 
portion of general business credit carryforwards to be 
transferred by certain taxpayers affected by federally 
declared disasters and other incidents. 
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 ‘‘Disaster Zone Energy 
Affordability and Investment Act’’. 
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SEC. 2. CERTAIN CARRYFORWARDS OF GENERAL BUSINESS 
CREDIT TREATED AS TRANSFERRABLE CRED-
ITS FOR TAXPAYERS AFFECTED BY CERTAIN 
DISASTERS. 
(a) IN GENERAL.—Section 6418(f)(1)(A) of the In-
ternal Revenue Code of 1986 is amended by adding at the 
end the following new clause: 
‘‘(xiii) so much of the amount of the 
applicable 
general 
business 
credit 
carryforwards as does not exceed the eligi-
ble expenditures made by the taxpayer dur-
ing the taxable year.’’. 
(b) APPLICABLE
GENERAL
BUSINESS
CREDIT 
CARRYFORWARDS.—Section 6418(f) of such Code is 
amended by adding at the end the following new para-
graph: 
‘‘(3) DEFINITIONS AND RULES RELATED TO AP-
PLICABLE
GENERAL
BUSINESS
CREDIT 
CARRYFORWARDS.—For 
purposes 
of 
paragraph 
(1)(A)(xiii)— 
‘‘(A) IN GENERAL.—The term ‘applicable 
general business credit carryforwards’ means, 
with respect to any taxable year, the sum of the 
amounts described in section 38(a)(1) which— 
‘‘(i) are carried to any taxable year 
beginning after December 31, 2023, and 
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‘‘(ii) attributable to any credit de-
scribed in clauses (ii) and (ix) of subpara-
graph (A). 
‘‘(B) ELIGIBLE EXPENDITURES.— 
‘‘(i) IN GENERAL.—The term ‘eligible 
expenditures’ means amounts paid or in-
curred by the taxpayer— 
‘‘(I) for the purpose of carrying 
out a trade or business in a qualified 
disaster area, and 
‘‘(II) on or before the last day of 
the second calendar year following the 
calendar year in which the declaration 
or determination described in clause 
(ii) with respect to such qualified dis-
aster area was made. 
‘‘(ii) QUALIFIED
DISASTER
AREA.— 
The term ‘qualified disaster area’ means— 
‘‘(I) any area with respect to 
which a major disaster was declared 
after December 31, 2023, by the 
President under section 401 of the 
Robert T. Stafford Disaster Relief 
and Emergency Assistance Act, or 
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‘‘(II) any area which is deter-
mined by the Governor of a State to 
be an area affected by a State de-
clared disaster (as defined in section 
165(h)(5)(C) of the Internal Revenue 
Code of 1986 (as added by Public 
Law 119–21)) if the incident giving 
rise to the State declared disaster oc-
curred after December 31, 2023. 
‘‘(C) APPLICATION
TO
CONSOLIDATED 
GROUPS.—All members of an affiliated group 
filing a consolidated return shall be treated as 
one taxpayer.’’. 
(c) 
CONFORMING
AMENDMENT.—Section 
6418(f)(1)(C) of such Code is amended by striking ‘‘The 
term’’ and inserting ‘‘Except as provided in paragraph 
(1)(A)(xiii), the term’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
(e) 
SPECIAL
RULE.—Notwithstanding 
section 
6418(g)(1) of the Internal Revenue Code of 1986, the Sec-
retary of the Treasury (or the Secretary’s delegate) shall 
not require registration with respect to the portion of any 
applicable general business credit carryforwards (as de-
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fined in section 6418(f)(3) of such Code, as added by this 
section) which relates to a taxable year beginning with or 
before the taxable year that the online registration tool 
for such registration has been updated to account for the 
provisions of this section. 
Æ 
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