Collegiate Housing and Infrastructure Act of 2025

Bill Number

H.R. 2355

Origin Chamber

House

Congress

119th Congress, Session 1

Policy Area

Taxation

Status

Introduced

Latest Action

2025-03-26: Referred to the House Committee on Ways and Means.

Last Updated

2026-06-04T08:08:57Z

AI-Generated Summary

Purpose

The Collegiate Housing and Infrastructure Act of 2025 aims to encourage charitable organizations to provide financial support for student housing and related infrastructure at colleges and universities. By amending the tax code, it ensures that such grants do not jeopardize the tax-exempt status of donating organizations, addressing potential shortages in affordable student housing.

Key Provisions

• Tax-Exempt Status for Grant Makers: Adds a new subsection to Section 501 of the Internal Revenue Code (IRC), allowing organizations exempt under 501(c)(3) (typically charities focused on educational or charitable purposes) to make "collegiate housing and infrastructure grants" to organizations exempt under 501(c)(7) (social or recreational clubs, such as student housing cooperatives) without losing their tax-exempt status.
• Definition of Eligible Grants: These grants can fund the provision, improvement, operation, or maintenance of "collegiate housing property." They may include more than minor social, recreational, or private uses, as long as the activities align with what a university dormitory or residential facility would typically allow. However, grants cannot fund physical fitness facilities (e.g., gyms).
• Definition of Collegiate Housing Property: Refers to properties where, at the time of the grant or after any funded acquisition, construction, lease, or modification, nearly all residents are full-time students enrolled at the nearby college or university.
• Grants to Title-Holding Entities: Grants to organizations that hold property solely for the benefit of a 501(c)(7) group are treated as direct grants to the benefiting organization.
• Effective Date: Applies to grants made in taxable years ending after the bill's enactment.

Significant Changes to Existing Law

• Expands the definition of "charitable or educational purposes" under IRC Section 501(c)(3) to explicitly include grants for student housing that involve social or recreational elements, which might otherwise be seen as non-charitable.
• Clarifies that such grants to 501(c)(7) organizations (previously limited in scope for tax purposes) are permissible if tied to student-focused housing, preventing automatic disqualification of the donor's tax-exempt status.
• Introduces specific exclusions (e.g., no funding for fitness facilities) and residency requirements to ensure grants stay focused on educational housing needs.

Potential Impacts

• On Government Agencies: The Internal Revenue Service (IRS) may see an increase in grant-related filings and audits to verify compliance with the new definitions, potentially requiring updated guidance or forms for tax-exempt organizations.
• On Citizens: Full-time college students could benefit from improved housing options, such as better-maintained dorms or cooperative residences, helping alleviate housing shortages and high costs near campuses. Donors to charities may feel more confident contributing to housing initiatives.
• On International Relations: No direct impacts, as the bill focuses on domestic U.S. tax policy for educational institutions.
• Broader Effects: Could lead to more private funding for campus infrastructure, reducing reliance on public funds and supporting student well-being during housing crises.

Main Stakeholders Affected

• Charitable and Educational Organizations: 501(c)(3) groups, which can now more freely make housing grants without tax risks.
• Student Housing Organizations: 501(c)(7) entities, such as student cooperatives or social clubs managing residences, which gain easier access to funding.
• Colleges and Universities: Benefit indirectly through improved housing for their students, potentially enhancing campus life and retention.
• Students and Donors: Students receive better housing support; individual or foundation donors support these efforts via tax-deductible contributions.
• Taxpayers and IRS: Indirectly involved through enforcement of the new rules.

Notable Legal, Constitutional, or Political Implications

• Legal Implications: Provides clearer IRS guidelines on what qualifies as charitable activity in student housing, reducing ambiguity and potential litigation over tax-exempt status. It aligns with existing tax deductions for charitable gifts (under IRC Sections 170, 2055, and 2522) but carves out a specific exception for housing grants.
• Constitutional Implications: None significant; the bill operates within Congress's taxing and spending powers under Article I of the U.S. Constitution and does not raise free speech, equal protection, or other constitutional concerns.
• Political Implications: Bipartisan sponsorship (from both parties) suggests broad support for addressing student housing needs. It could set a precedent for future tax incentives in education infrastructure, potentially influencing debates on higher education affordability without increasing federal spending.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Sponsor

Rep. Moore, Blake D. [R-UT-1]

Cosponsors (23)

Rep. Sewell, Terri A. [D-AL-7], Rep. Fitzpatrick, Brian K. [R-PA-1], Rep. Davis, Danny K. [D-IL-7], Rep. Kelly, Mike [R-PA-16], Rep. Lee, Susie [D-NV-3], Rep. Sessions, Pete [R-TX-17], Rep. DelBene, Suzan K. [D-WA-1], Rep. Rogers, Mike D. [R-AL-3], Rep. Craig, Angie [D-MN-2], Rep. Murphy, Gregory F. [R-NC-3], Rep. Mann, Tracey [R-KS-1], Rep. Thompson, Glenn [R-PA-15], Rep. Johnson, Dusty [R-SD-At Large], Rep. Kustoff, David [R-TN-8], Rep. McBath, Lucy [D-GA-6], Rep. Haridopolos, Mike [R-FL-8], Rep. Fry, Russell [R-SC-7], Rep. Williams, Roger [R-TX-25], Rep. Hinson, Ashley [R-IA-2], Rep. Aderholt, Robert B. [R-AL-4], Rep. DeSaulnier, Mark [D-CA-10], Rep. Rouzer, David [R-NC-7], Rep. Schmidt, Derek [R-KS-2]

Recent Actions

• 2025-03-26: Referred to the House Committee on Ways and Means.
• 2025-03-26: Introduced in House
• 2025-03-26: Introduced in House

Bill Versions

• Collegiate Housing and Infrastructure Act of 2025 — issued 2025-03-26 — PDF (4 pages)