The enactment of Section 25F of the Internal Revenue Code—part of the One Big Beautiful Bill Act (P.L. 119-21)—is one of the most significant developments in education-related tax policy in a generation. Building on decades of state-level tax credit scholarship programs, Congress has established a federal framework that channels private philanthropic capital into K-12 scholarships through a new qualifying vehicle: the Scholarship Granting Organization (“SGO”). For schools, charities, and foundations invested in educational access, the moment calls for informed strategic planning.
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