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S 1810119th CongressIn Committee

Universal School Choice Act

Introduced: May 20, 2025
Economy & TaxesEducation
Standard Summary
Comprehensive overview in 1-2 paragraphs

The Universal School Choice Act would create a nationwide federal tax credit program to encourage charitable donations to scholarship granting organizations that provide scholarships for qualified elementary and secondary education expenses to eligible students. Individuals could claim a credit for the amount they donate (subject to income-based and annual volume caps), and corporations could claim a separate credit for their qualified contributions. The act sets a national volume cap, allocates a portion of that cap to states, and requires donors to designate a distribution state. Scholarships funded under the program could cover a wide range of qualified education expenses, including tuition, books, tutoring, online materials, certain therapies, and homeschooling costs. The bill also establishes governance and accountability requirements for scholarship granting organizations, creates protections for parental choice, and imposes penalties if organizations fail to distribute receipts as required. In addition, it provides tax-exemption for scholarship-related scholarships and expands parental autonomy in the school-choice framework. In short, the bill would shift some federal tax dollars toward private and nonprofit scholarship funding instead of direct public funding for schools, with a centralized cap and state-based allocation, enhanced oversight, and a strong emphasis on parental choice and autonomy.

Key Points

  • 1Creation of a federal tax credit (Sec. 25F for individuals; Sec. 45BB for corporations) for qualified contributions to scholarship granting organizations that fund elementary and secondary education scholarships. The individual credit is limited by AGI or a $5,000 floor, and the corporate credit is capped at 5% of taxable income. There is a “no double benefit” rule (no deduction for the same expense).
  • 2A national volume cap of $10 billion (starting in 2026) with state-by-state allocations. Donors designate a distribution state, and allocations to each state follow a formula based on state population of 5-17-year-olds and families in poverty, with a minimum allocation guarantee. The cap can be adjusted upward after high-use years, and credits are tracked in real time.
  • 3Establishment and strict oversight of scholarship granting organizations. Requirements include: (a) non-profit status focused on scholarships, (b) independent audits, (c) safeguards against self-dealing, (d) income verification for priority eligibility, and (e) priority scholarship distribution rules favoring returning students, siblings, and low-income households (up to 500% of the poverty line). The bill also prohibits payments to family members for qualified expenses and requires compliance with distribution deadlines.
  • 4New provisions on scholarships’ tax treatment and administration. Scholarships used to pay eligible expenses are exempt from gross income (for recipients), while qualified contributions used for these scholarships are not deductible as charitable contributions for other purposes. The act also creates a new enforcement mechanism (Sec. 4969) for failures to distribute receipts by scholarship organizations, with consequences for future contributions.
  • 5Strong emphasis on parental autonomy. The bill asserts that scholarship organizations operate independently of governmental control, protects parental rights to use scholarships at private or religious schools, and allows parents to intervene in related constitutional challenges.

Impact Areas

Primary group/area affected- Eligible students and their families who participate in scholarship programs, including those attending private or religious schools or homeschooling with eligible expenses.- Donors to scholarship granting organizations (individuals and corporations) who would receive federal tax credits for their contributions.- Scholarship granting organizations (nonprofits meeting specific audits, governance, and distribution requirements).Secondary group/area affected- Private and religious elementary and secondary schools that would receive scholarships funded by these contributions.- State and local governments, and state-based education policy, due to the volume-cap allocation and designated distribution states.- Public schools and public education funding may experience indirect effects as funds shift toward scholarships.Additional impacts- Administrative and compliance costs for scholarship organizations (audits, income verification, tracking of distributions, and real-time reporting).- Potential changes to charitable giving patterns due to the volume cap, state allocations, and cross-state donation flows.- Legal and constitutional considerations tied to parental rights and school-choice provisions, with a provision allowing parental intervention in related lawsuits.- Tax administration changes, including the treatment of scholarships under gross income rules and AMT considerations for taxpayers utilizing the credits.- Safeguards against misuse (e.g., prohibitions on related-party payments, self-dealing, and ensuring funds reach eligible students) and penalties for non-distribution of receipts.
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