(c) INVESTMENT LIMITATION ON NON-U.S. INDIVID-
UALS AND ENTITIES.—Notwithstanding any other provi-
sion of law— 
(1) non-U.S. individuals and entities may not 
hold more than 25 percent, in the aggregate, of the 
equity securities and bonds of the Holding Company; 
and 
(2) nothing in this section shall prevent non- 
U.S. individuals and entities that are shareholders 
from receiving equity shares and dividend payments. 
SEC. 6. OVERSIGHT AND REGULATION. 
(a) BOARD OF GOVERNORS OF THE FEDERAL RE-
SERVE SYSTEM.—The Board of Governors of the Federal 
Reserve System shall have oversight and supervisory au-
thority over the Holding Company and the Bank in order 
to ensure the safe and sound operation of the Holding 
Company and the Bank. 
(b) SECRETARY OF THE TREASURY.—The Secretary 
shall oversee and supervise the issuance of bonds by the 
Holding Company and the Bank, in order to ensure the 
safe and sound financing of the Holding Company and the 
Bank. 
(c) CONSULTATION.—The Secretary shall consult 
with the Board of Governors of the Federal Reserve Sys-
tem and may consult with the Secretary of Transportation 
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and any other head of Federal agency when carrying out 
the Secretary’s duties under this Act. 
SEC. 7. INFRASTRUCTURE GUARANTEE FUND. 
(a) ESTABLISHMENT.—The Bank shall establish an 
Infrastructure Guarantee Fund that shall be available for 
State and local governments and other persons who wish 
to deposit funds to be used with respect to specific loans 
or loan guarantees made by the Bank in the event of any 
non-payment by the recipient of such loan or loan guar-
antee. 
(b) RETURN OF FUNDS.—Any funds described under 
subsection (a) that are remaining at the time such loans 
or guaranteed loans are repaid in full shall be returned 
to the State or local government or other person who de-
posited the funds. 
SEC. 8. HOLDING COMPANY AND BANK EXEMPTION FROM 
TAXATION. 
Effective for taxable years ending on or after the date 
of enactment of this Act, the Holding Company and the 
Bank, including franchises, capital, reserves, surplus, ad-
vances, and income of the Holding Company or Bank shall 
be exempt from all taxation imposed by the United States, 
by any territory, dependency, or possession thereof, or by 
any State, county, municipal, or local taxing authority, ex-
cept that any real property of the Holding Company and 
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the Bank shall be subject to State, territorial, county, mu-
nicipal, or local taxation to the same extent according to 
its value as other real property is taxed. 
SEC. 9. INFRASTRUCTURE BANK HOLDING COMPANY CRED-
IT. 
(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. 45U. 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 In-
frastructure Bank Holding Company credit determined 
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 
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‘‘(2) each of the 4 anniversary dates of such 
date thereafter. 
‘‘(c) QUALIFIED HOLDING COMPANY EQUITY IN-
VESTMENT.—For purposes of this section, the term ‘quali-
fied Holding Company equity investment’ means any eq-
uity investment originally issued by the Holding Company 
to the taxpayer under section 5(a)(1) of the Infrastructure 
Bank for America Act of 2020 not later than 3 years after 
the date of the enactment of such Act. 
‘‘(d) HOLDING COMPANY.—For purposes of this sec-
tion, the term ‘Holding Company’ means the Infrastruc-
ture Bank Holding Company established by the Infra-
structure Bank for America Act of 2020. 
‘‘(e) BASIS REDUCTION.—The basis of any qualified 
Holding Company equity investment shall be reduced by 
the amount of any credit determined under this section 
with respect to such investment.’’; and 
(2) in the table of contents for such subpart, by 
adding at the end the following: 
‘‘45U. 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 (32), by 
striking the period at the end of paragraph (33) and 
inserting ‘‘, plus’’, and by adding at the end the fol-
lowing new paragraph: 
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‘‘(34) the Infrastructure Bank Holding Com-
pany credit determined under section 45U.’’. 
(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: 
‘‘(39) to the extent provided in section 
45U(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. 10. 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. 
SEC. 11. DEFINITIONS. 
For the purposes of this Act: 
(1) BANK.—The term ‘‘Bank’’ means the Infra-
structure Bank for America established under sec-
tion 3. 
(2) FORMATION AGENT.—The term ‘‘formation 
agent’’ means an entity selected by the Secretary of 
the Treasury with significant experience in infra-
structure and infrastructure finance. 
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