HR3519-119

Introduced

To amend the Internal Revenue Code of 1986 to allow a credit against tax for charitable donations to nonprofit organizations providing education scholarships to qualified elementary and secondary students.

119th Congress Introduced May 20, 2025

Summary

What This Bill Does

The bill amends the Internal Revenue Code to insert new Section 25F creating an individual tax credit for qualified contributions to scholarship granting organizations, capped at the greater of 10% of AGI or $5,000, with volume, creates full text of new IRC Section 25F providing the individual education scholarship tax credit, detailing credit amount, AGI/K cap, volume cap limitations, state credit offset, and definitions including eligible, and creates new IRC Section 45BB providing a general business credit for corporate contributions to scholarship granting organizations, capped at 5% of taxable income, with no deduction allowed for credited contributions. It relies on tax credits, tax exemption, tax penalty, and reporting requirements. The main policy areas are Education.

Who Benefits and How

Scholarship granting organizations could gain revenue opportunities, Private and religious K-12 schools could face lower compliance burdens, and Private and religious elementary and secondary schools could gain revenue opportunities.

Who Bears the Burden and How

Federal Treasury could lose revenue opportunities, Public school systems could lose revenue opportunities, and Federal government (revenue loss) could face higher costs.

Key Provisions

  • Amends the Internal Revenue Code to insert new Section 25F creating an individual tax credit for qualified contributions to scholarship granting organizations, capped at the greater of 10% of AGI or $5,000, with volume...
  • Creates full text of new IRC Section 25F providing the individual education scholarship tax credit, detailing credit amount, AGI/K cap, volume cap limitations, state credit offset, and definitions including eligible...
  • Creates new IRC Section 45BB providing a general business credit for corporate contributions to scholarship granting organizations, capped at 5% of taxable income, with no deduction allowed for credited contributions.
  • Creates new IRC Section 4969 disqualifying contributions to scholarship granting organizations that fail to distribute at least 100% of receipts (less reasonable admin expenses up to 10%) within 3 years, effectively...
  • Establishes a $10 billion annual volume cap on scholarship tax credits, allocated to states based on child population (20% weight) and child poverty (80% weight), with a minimum state allocation of 0.5%, reservation...

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

The bill amends the Internal Revenue Code to insert new Section 25F creating an individual tax credit for qualified contributions to scholarship granting organizations, capped at the greater of 10% of AGI or $5,000, with volume, creates full text of new IRC Section 25F providing the individual education scholarship tax credit, detailing credit amount, AGI/K cap, volume cap limitations, state credit offset, and definitions including eligible, and creates new IRC Section 45BB providing a general business credit for corporate contributions to scholarship granting organizations, capped at 5% of taxable income, with no deduction allowed for credited contributions.

Key Policy Areas

Education

Primary Purpose

The bill amends the Internal Revenue Code to insert new Section 25F creating an individual tax credit for qualified contributions to scholarship granting organizations, capped at the greater of 10% of AGI or $5,000, with volume, creates full text of new IRC Section 25F providing the individual education scholarship tax credit, detailing credit amount, AGI/K cap, volume cap limitations, state credit offset, and definitions including eligible, and creates new IRC Section 45BB providing a general business credit for corporate contributions to scholarship granting organizations, capped at 5% of taxable income, with no deduction allowed for credited contributions.

Policy Domains

Education

Section 2 — Individual Tax Credit (Section 25F)

Identified Gains
  • Scholarship granting organizations
  • Private and religious K-12 schools
  • Private and religious elementary and secondary schools
  • K-12 scholarship recipients
  • Individual taxpayers making charitable education contributions
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: ih
K-12 scholarship recipients:
Private and religious K-12 schools: ,
Scholarship granting organizations: , , ,
Private and religious elementary and secondary schools:
Individual taxpayers making charitable education contributions:
Identified Costs
  • Federal Treasury
  • Public school systems
  • Federal government (revenue loss)
  • Scholarship granting organizations
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: ih
Federal Treasury: , ,
Public school systems: ,
Federal government (revenue loss):
Scholarship granting organizations:

Legislative Progress

Introduced
Introduced Committee Passed
May 20, 2025

Mr. Owens (for himself and Mr. Donalds) introduced the following …

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Education
17 mentions across 8 clauses
+14 positive -3 negative

Families choosing private/religious K-12 education, Families receiving K-12 scholarships from SGOs, K-12 scholarship recipients

Scholarship granting organizations faces effects in multiple directions

Positive-direction: Families choosing private/religious K-12 education, Families receiving K-12 scholarships from SGOs, K-12 scholarship recipients, Low-income families seeking private education, Parents choosing private education, Private and religious K-12 schools, Private and religious elementary and secondary schools, Private and religious schools, Scholarship recipients

Negative-direction: Public school systems

Government
6 mentions across 4 clauses
+2 positive -4 negative

Federal Treasury, Federal government (revenue loss), High-poverty states

Positive-direction: High-poverty states, States with large child populations

Negative-direction: Federal Treasury, Federal government (revenue loss)

Business Associations
1 mention across 1 clause
+1 positive

Corporations making education contributions

Taxpayers
1 mention across 1 clause
+1 positive

Individual taxpayers making charitable education contributions

8/9
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Education
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Education
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Education
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Education
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Education
Domains
Education

Key Definitions

Terms defined in this bill

4 terms
"eligible student" §25F(c)(1)

An individual who is eligible to enroll in a public elementary or secondary school.

"qualified contribution" §25F(c)(2)

A charitable contribution in cash or marketable securities to a scholarship granting organization.

"qualified elementary or secondary education expense" §25F(c)(3)

Tuition, fees, tutoring, special needs services, textbooks, supplies, technology, transportation, and other education-related expenses.

"scholarship granting organization" §25F(c)(4)

A 501(c)(3) organization that provides scholarships for qualified K-12 education expenses, with more than 90% of receipts going to scholarship purposes.

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology