S1810-119

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 creates new IRC Section 25F creating individual tax credit for contributions to scholarship granting organizations for K-12 private education, creates IRC Section 25F statutory text for individual education scholarship tax credit with definitions of eligible students, qualified contributions, scholarship granting organizations, and qualified expenses, and creates new IRC Section 45BB creating corporate education scholarship tax credit for contributions to scholarship granting organizations, capped at 5% of taxable income. It relies on tax credits, exemptions, definition changes, and compliance mandates. The main policy areas are Education.

Who Benefits and How

Scholarship granting organizations could gain revenue opportunities, Families receiving education scholarships could see lower costs, and Private and religious K-12 schools could face fewer barriers.

Who Bears the Burden and How

Federal Treasury could face higher costs, Scholarship granting organizations would take on compliance duties, and Federal, state, and local government education agencies could face higher barriers.

Key Provisions

  • Creates new IRC Section 25F creating individual tax credit for contributions to scholarship granting organizations for K-12 private education.
  • Creates IRC Section 25F statutory text for individual education scholarship tax credit with definitions of eligible students, qualified contributions, scholarship granting organizations, and qualified expenses.
  • Creates new IRC Section 45BB creating corporate education scholarship tax credit for contributions to scholarship granting organizations, capped at 5% of taxable income.
  • Requires new IRC Section 4969 imposing penalty on scholarship granting organizations that fail to distribute 100% of receipts within 3 years (minus up to 10% for administrative expenses).
  • Establishes a $10 billion annual volume cap on education scholarship tax credits, allocated among states based on student population (20%) and poverty rates (80%), with Treasury Department administration.

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 creates new IRC Section 25F creating individual tax credit for contributions to scholarship granting organizations for K-12 private education, creates IRC Section 25F statutory text for individual education scholarship tax credit with definitions of eligible students, qualified contributions, scholarship granting organizations, and qualified expenses, and creates new IRC Section 45BB creating corporate education scholarship tax credit for contributions to scholarship granting organizations, capped at 5% of taxable income.

Key Policy Areas

Education

Primary Purpose

The bill creates new IRC Section 25F creating individual tax credit for contributions to scholarship granting organizations for K-12 private education, creates IRC Section 25F statutory text for individual education scholarship tax credit with definitions of eligible students, qualified contributions, scholarship granting organizations, and qualified expenses, and creates new IRC Section 45BB creating corporate education scholarship tax credit for contributions to scholarship granting organizations, capped at 5% of taxable income.

Policy Domains

Education

Section 2 - Tax Credit for Contributions to Scholarship Granting Organizations

Identified Gains
  • Scholarship granting organizations
  • Families receiving education scholarships
  • Private and religious K-12 schools
  • Individual taxpayers making charitable contributions
  • Corporations making charitable contributions
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
Private and religious K-12 schools: ,
Scholarship granting organizations: , , ,
Families receiving education scholarships: ,
Corporations making charitable contributions:
Individual taxpayers making charitable contributions:
Identified Costs
  • Federal Treasury
  • Scholarship granting organizations
  • Federal, state, and local government education agencies
  • Public school systems
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
Federal Treasury:
Public school systems:
Scholarship granting organizations:
Federal, state, and local government education agencies:

Legislative Progress

Introduced
Introduced Committee Passed
May 20, 2025

Mr. Cruz introduced the following bill; which was read twice …

Stakeholder Effects

cui bono?

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

Education
10 mentions across 6 clauses
+8 positive -2 negative

Private and religious K-12 schools, Private and religious elementary and secondary schools, Public school systems

Scholarship granting organizations faces effects in multiple directions

Positive-direction: Private and religious K-12 schools, Private and religious elementary and secondary schools, Scholarship granting organizations (501(c)(3) nonprofits)

Negative-direction: Public school systems

Tax-Advantaged Charitable Giving
2 mentions across 2 clauses
+2 positive

Individual taxpayers, Individual taxpayers making charitable contributions

Government
2 mentions across 2 clauses
-2 negative

Federal Treasury, Federal, state, and local government education agencies

Consumers
2 mentions across 2 clauses
+2 positive

Families receiving education scholarships

State & Local Government
1 mention across 1 clause
+1 positive

States with high poverty student populations

Corporate Tax
1 mention across 1 clause
+1 positive

Corporations making charitable 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 Policy Education
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
Domains
Tax Policy
Domains
Education Civil Rights

Key Definitions

Terms defined in this bill

4 terms
"eligible student" §25F(c)(1)

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

"qualified contribution" §25F(c)(2)

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

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

Expenses including tuition, curricula, books, instructional materials, online materials, tutoring, testing, special needs services, transportation, uniforms, and other approved expenses

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

A 501(c)(3) nonprofit that provides scholarships for qualified education expenses and allocates at least 90% of receipts to scholarships

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