Source Documents
Statute
IRC Section 25F — Education Freedom Tax Credit
Section 25F, added by the One Big Beautiful Bill Act (Public Law 119-21), creates a federal income tax credit for individuals who make charitable contributions to Scholarship Granting Organizations.
IRC Section 139K — Scholarship Income Exclusion
Provides that gross income does not include amounts provided to a student under a scholarship for qualified elementary or secondary education expenses.
IRC Section 530(b)(3) — Qualified K-12 Expenses
Section 530 is the Coverdell education-savings-account statute; subsection (b)(3) defines the term "qualified elementary and secondary education expenses."
Legislative Provision
One Big Beautiful Bill Act, Section 70411
Signed July 4, 2025 (Public Law 119-21), Section 70411 added Section 25F (the donor credit) and related provisions to the Internal Revenue Code.
IRS Guidance
Notice 2025-70 — Request for Comments
The first IRS guidance interpreting new Section 25F, requesting public comment on open questions ahead of proposed regulations.
Revenue Procedure 2026-6 — State Advance Election
The route by which a state opts in so its Scholarship Granting Organizations can qualify donors for the Section 25F credit in 2027.
IRS Program Page — Federal Scholarship Tax Credit
The IRS's official program page; confirms that starting January 1, 2027, an individual taxpayer may claim the credit.
News Release IR-2026-76
On June 8, 2026 the IRS announced that more than half the states had elected to participate in the federal scholarship tax credit under Section 25F.
Treasury
Preview of Forthcoming Section 25F Guidance
On June 10, 2026 Treasury released a preview of the regulatory framework it expects to propose for the new Section 25F credit.
Treasury Previews EFTC Guidance
Treasury announced it had previewed forthcoming Treasury and IRS guidance for the new federal Education Freedom Tax Credit.
Coming Soon
IRS Donor Claim Form (number TBA)
The IRS form and instructions a donor will use to claim the nonrefundable Section 25F credit for a contribution to an SGO.
Proposed Regulations under Section 25F
Treasury and the IRS expect to issue proposed (not yet final) regulations under Section 25F by the end of September 2026.
