Notice 2025-70
Details
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- Title
- Notice 2025-70
- Posted
- Dec 1, 2025
- Comment period
- Dec 1, 2025 – Dec 27, 2025
- Topics
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Stance breakdown
Who commented
Breakdown by commenter type.
Comments over time
Weekly arrivals, stacked by stance.
Support × commenter type
How each type splits across stance.
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | School choice | Federal preemption | Sgo certification standards | Married filing status eligibility | Interstate residency eligibility |
|---|---|---|---|---|---|
4 Public Education AdvocacyOppose The Board of Directors for 4 Public Education opposes the proposed federal tax credit voucher program, arguing that it d | · | · | · | · | |
AAA Scholarship Foundation AdvocacySupport The AAA Scholarship Foundation, a multi-state scholarship granting organization, supports the proposed federal education | · | · | · | ||
AFT UnionOppose The American Federation of Teachers (AFT) opposes the proposed tax credit for private school scholarships, arguing that | · | · | · | ||
Afterschool Alliance AdvocacySupport The Afterschool Alliance, a national nonprofit, supports the new federal tax credit scholarship program and provides spe | · | · | |||
Agudath Israel of New England AdvocacySupport Agudath Israel of New England, a nonprofit representing Jewish day schools, supports the Federal Scholarship Tax Credit | · | · | · | · | |
Alabama Expanded Learning Alliance (AELA) AdvocacySupport The Alabama Expanded Learning Alliance supports the new federal tax credit for scholarship granting organizations and ad | · | · | · | ||
Alabama Opportunity Scholarship Fund AdvocacySupport The Alabama Opportunity Scholarship Fund, an organization representing families and schools, supports the proposed actio | · | · | · | ||
Alliance for Choice in Education and ACE Scholarships Federal Tax Credit SGO AdvocacySupport Alliance for Choice in Education (ACE Scholarships) and ACE Scholarships Federal Tax Credit SGO support the proposed reg | · | · | |||
Alpha Holdco, LLC BusinessSupport Alpha Holdco, LLC, a company with experience in educational philanthropy, supports the Education Choice Tax Credit but a | · | · | · | · | |
America First Policy Institute AdvocacySupport The America First Policy Institute (AFPI) supports the proposed federal scholarship tax credit, viewing it as a way to e | · | · | |||
American Association of Christian Schools AdvocacySupport The American Association of Christian Schools (AACS) supports the federal student tax credit scholarship provision but r | · | · | |||
American Humanist Association AdvocacyOppose The American Humanist Association opposes the proposed tax credit for scholarship granting organizations, arguing that i | · | · | · | · | |
Americans United for Separation of Church and State AdvocacySupport Americans United for Separation of Church and State supports the proposed tax credit but argues that the Treasury Depart | · | · | · | ||
Arizona Superintendents from Greater Phoenix Educational Management Council/Arizona Educational Management Council GovernmentSupport A coalition of Arizona public school leaders is providing feedback on the "Federal Tax Credits for Education Scholarship | · | · | · | ||
Association of Christian Schools International AdvocacySupport The Association of Christian Schools International (ACSI) supports the Federal Scholarship Tax Credit (FSTC) and provide | · | · | |||
Association of Educational Service Agencies and Association of School Business Officials International AdvocacySupport The Association of Educational Service Agencies (AESA) and the Association of School Business Officials International (A | · | · | · | ||
Baptist Joint Committee for Religious Liberty AdvocacySupport A coalition of national faith-based organizations (Baptist Joint Committee for Religious Liberty, Cooperative Baptist Fe | · | · | · | · | |
Benjamin and Lillian Rochkind Yeshiva of Virginia AdvocacySupport Stuart Cantor, representing the Benjamin & Lillian Rochkind Yeshiva of Virginia, argues that the Treasury should interpr | · | · | · | · | |
BLOCS - Business Leaders Organized for Catholic Schools AdvocacySupport Business Leadership Organized for Catholic Schools (BLOCS), a large scholarship granting organization, supports the new | · | · | |||
Boys & Girls Clubs of America AdvocacySupport The Boys & Girls Clubs of America (BGCA) supports the implementation of the individual tax credit for scholarship granti | · | · | · | ||
California Association of Private School Organizations (CAPSO) AdvocacySupport The California Association of Private School Organizations (CAPSO) submits comments providing specific recommendations t | · | · | · | ||
Catholic Conference of Illinois AdvocacySupport The Catholic Conference of Illinois, representing the Illinois bishops and lay Catholics, supports the proposed tax cred | · | · | · | ||
Center for American Progress AdvocacySupport The Center for American Progress supports the implementation of the new tax credit for scholarship granting organization | · | · | · | · | |
Center for Arizona Policy AdvocacySupport The Center for Arizona Policy (CAP) supports the implementation of the new federal individual tax credit for contributio | · | · | |||
Center for Christian Virtue and the Christian Education Network AdvocacySupport The Center for Christian Virtue (CCV), a public policy organization, supports the proposed federal school choice tax cre | · | · | · | ||
Center for Learner Equity AdvocacySupport The Center for Learner Equity, a nonprofit organization advocating for students with disabilities, supports the developm | · | · | · | · | |
Children's Funding Project AdvocacySupport The Children’s Funding Project, a national nonprofit social impact organization, supports the proposed tax credit progra | · | · | · | · | |
Children's Scholarship Fund AdvocacySupport The Children’s Scholarship Fund (CSF) supports the implementation of Section 25F and recommends that the IRS expressly p | · | · | · | · | · |
Christian Legal Society AdvocacySupport The Christian Legal Society (CLS) supports the new federal tax credit scholarship program and provides specific recommen | · | · | |||
Coalition for Education Equity of Alaska AdvocacyOppose The Coalition for Education Equity, representing several Alaska school districts, opposes the proposed federal tax credi | · | · | · | ||
Colorado Association of Private Schools Trade associationSupport The Colorado Association of Private Schools supports the Federal Scholarship Tax Credit Program but urges the Treasury t | · | · | · | ||
Connecticut Education Association UnionOppose The Connecticut Education Association, a union representing educators, opposes the proposed tax credit scholarship progr | · | · | · | ||
Council for American Private Education (CAPE) AdvocacySupport The Council for American Private Education (CAPE) is submitting comments on the proposed rulemaking for the Federal Scho | · | · | |||
Design With Joy LLC AdvocacySupport Nicodemus, representing the Rural Professional Learning Network and Joy LLC, supports the federal scholarship tax credit | · | · | · | · | |
EdChoice AdvocacySupport EdChoice, a nonpartisan educational choice organization, supports the implementation of the Section 25F federal tax cred | · | · | · | · | |
EdTrust AdvocacySupport EdTrust is commenting on the implementation of a new federal tax credit for contributions to Scholarship Granting Organi | · | · | · | ||
Education Law Center- PA AdvocacyOppose The Education Law Center-PA (ELC-PA) opposes the federal private school voucher program, arguing that it fails to improv | · | · | · | · | |
EducationCounsel AdvocacySupport EducationCounsel, a nonpartisan education organization, supports the proposed tax credit but urges the Treasury Departme | · | · | · | · | |
Every Hour Counts AdvocacySupport Every Hour Counts, a national network of citywide intermediary organizations supporting expanded learning, supports the | · | · | · | ||
Federal Scholarship Tax Credit Coalition AdvocacySupport The Federal Scholarship Tax Credit (FSTC) Coalition, representing over 200 school choice advocates and religious organiz | · | · | |||
FGA Action AdvocacySupport FGA Action supports the implementation of the Federal Scholarship Tax Credit (FSTC) but urges the IRS to adopt specific | · | · | · | ||
Fight Crime: Invest in Kids AdvocacySupport The Institute for Child Success, representing a membership group of law enforcement officials, supports the proposed tax | · | · | · | · | · |
First Day PR AdvocacySupport The ESP Coalition, representing a group of education service providers, supports the implementation of the federal Schol | · | · | · | ||
Georgia GOAL Scholarship Program, Inc. AdvocacySupport The Georgia GOAL Scholarship Program, Inc., an organization with extensive experience in state tax credit scholarship pr | · | · | |||
IDRA AdvocacyOppose The Institute for Development of Rural America (IDRA), a national nonprofit organization, opposes the implementation of | · | · | · | · | · |
IFPC Legal Center AdvocacySupport The Idaho Family Policy Center Legal Center supports the proposed tax credit but argues that the IRS should interpret "t | · | · | · | · | |
Illinois Families for Public Schools AdvocacyOppose Illinois Families for Public Schools opposes the proposed federal tax expenditure that would allow public funds to be us | · | · | · | · | |
Illinois Policy AdvocacySupport Illinois Policy, a nonpartisan public policy advocacy organization, urges the Department of the Treasury and the IRS to | · | · | · | ||
Invest in Education AdvocacySupport The Invest in Education Coalition, representing a large group of scholarship granting organizations (SGOs), supports the | · | · | · | · | · |
Jewish Federation of Greater Seattle and the Samis Foundation AdvocacySupport The Samis Foundation and the Jewish Federation of Greater Seattle support the implementation of the Federal Scholarship | · | · | |||
Jewish Federations of North America AdvocacySupport The Jewish Federations of North America supports the creation of the individual tax credit for scholarship granting orga | · | · | · | ||
Learning Heroes AdvocacySupport Learning Heroes, a national nonprofit focused on home-school partnerships, supports the new federal tax credit for Schol | · | · | · | · | · |
LearningSpring AdvocacySupport LearningSpring, an enterprise software provider for the scholarship sector, supports the implementation of Section 25F b | · | · | · | ||
Maryland Council for American Private Education (CAPE) AdvocacySupport The Maryland Council for American Private Education (CAPE) supports the Federal Scholarship Tax Credit Program but reque | · | · | · | · | |
Michigan Forward Network AdvocacySupport Michigan Forward Network, an advocacy organization, supports the Federal Scholarship Tax Credit and urges the IRS to ens | · | · | · | · | |
Montana Federation of Public Employees UnionOppose The Montana Federation of Public Employees (MFPE) opposes the proposed tax credit for scholarship granting organizations | · | · | · | ||
My Church SGO AdvocacySupport My Church SGO, an advocacy organization, strongly supports the new nonrefundable tax credit for contributions to Scholar | · | · | · | · | |
NAIS, AISAP, CASE, EMA/ERB, NBOA, TABS AdvocacySupport A coalition of independent school associations (including NAIS, AISAP, CASE, EMA/ERB, NBOA, and TABS) submitted comments | · | · | |||
National Alliance for Public Charter Schools AdvocacySupport The National Alliance for Public Charter Schools supports the Federal Scholarship Tax Credit (FSTC) program and recommen | · | · | · | · | |
National Catholic Educational Association AdvocacySupport The National Catholic Educational Association (NCEA) supports the implementation of the Federal Scholarship Tax Credit ( | · | · | |||
National Center for Learning Disabilities AdvocacySupport The Arc of the United States and several other special education organizations are urging the Department of Treasury to | · | · | · | · | |
National Down Syndrome Congress AdvocacySupport The National Down Syndrome Congress (NDSC) supports the proposed tax credit for scholarship granting organizations but u | · | · | · | · | · |
National Education Association AdvocacyOppose The National Education Association (NEA) opposes the proposed federal tax credit for scholarship granting organizations, | · | · | · | ||
National Education Association Rhode Island AdvocacyOppose The National Education Association Rhode Island (NEARI) opposes the implementation of § 25F, arguing that the federal ta | · | · | · | ||
National Math Stars AdvocacySupport National Math Stars, an organization supporting gifted students in math and science, supports the new Federal Scholarshi | · | · | |||
National School Boards Association AdvocacySupport The National School Boards Association (NSBA) supports the proposed individual tax credit for contributions to Scholarsh | · | · | · | ||
Nebraska Association of School Boards AdvocacyOther The Nebraska Association of School Boards expresses concern that the proposed tax credits for contributions to Scholarsh | · | · | · | ||
New America AdvocacySupport New America, a nonprofit policy and research organization, supports the implementation of the Individual Tax Credit for | · | · | · | · | |
New Jersey Council for American Private Education AdvocacySupport The New Jersey Council for American Private Education (NJCAPE) submitted comments providing specific recommendations to | · | · | |||
New Jersey Jewish Education Fund AdvocacySupport The New Jersey Jewish Education Fund (NJJEF), a 501(c)(3) public charity, supports the implementation of the Educational | · | · | · | · | |
North Carolina Budget & Tax Center AdvocacyOppose The NC Budget & Tax Center, a non-profit organization, strongly opposes the federal voucher program, arguing that it div | · | · | · | · | |
Ohio Association of Independent Schools Scholarship Granting Organization AdvocacySupport The Ohio Association of Independent Schools Scholarship Granting Organization (OAIS SGO) supports the implementation of | · | · | |||
Our Schools Our Democracy AdvocacyOppose Our Schools Our Democracy (OSOD) opposes the proposed federal tax credit for contributions to scholarship-granting organ | · | · | · | · | |
Peach State Education Partnership AdvocacySupport The Peach State Education Partnership, representing Georgia educators and school leaders, supports the new tax credit fo | · | · | · | ||
PEER Illinois AdvocacyOppose The Partnership for Equity and Education Rights Illinois (PEER Illinois) expresses strong opposition to the federal priv | · | · | · | · | |
Pennsylvania Council for American Private Education AdvocacySupport The Pennsylvania Council for American Private Education (PACAPE) submitted comments supporting the Federal Scholarship T | · | · | |||
Pioneer New England Legal Foundation AdvocacySupport The Pioneer New England Legal Foundation, a nonprofit legal research and litigation entity, argues that the IRS should c | · | · | · | · | |
Public Funds Public Schools AdvocacyOppose Public Funds Public Schools, a national campaign directed by the Education Law Center, strongly opposes the proposed fed | · | · | · | · | |
Public Schools First North Carolina AdvocacyOppose Public Schools First North Carolina, a nonpartisan nonprofit, opposes the federal voucher program, arguing that it diver | · | · | · | · | |
Roth & Company LLP BusinessSupport Roth & Company LLP, a law firm representing nonprofit clients, supports the proposed implementation of IRC § 25F but urg | · | · | · | · | |
Save Our Schools Arizona AdvocacyOppose Save Our Schools Arizona, an advocacy organization, strongly opposes the federal voucher program and its associated regu | · | · | · | · | |
Shepherds, Inc. AdvocacySupport Shepherds, Inc., a non-profit organization, supports the proposed regulations but requests specific clarifications and f | · | · | · | · | |
Slater Torah Academy AdvocacySupport The executive director of Slater Torah Academy, an organization involved in school choice advocacy, supports the propose | · | · | · | · | |
South Dakota Partners in Education AdvocacySupport South Dakota Partners in Education, a scholarship granting organization, supports the creation of the federal scholarshi | · | · | · | ||
Southeastern District LCMS AdvocacySupport The Southeastern District of the Lutheran Church—Missouri Synod (LCMS) supports the implementation of the Educational Ch | · | · | · | · | |
STEM Next Opportunity Fund AdvocacySupport STEM Next Opportunity Fund, a national nonprofit organization, supports the proposed tax credit for scholarship granting | · | · | · | · | |
Step Up For Students AdvocacySupport Step Up For Students (SUFS), a non-profit organization, supports the implementation of the federal scholarship tax credi | · | · | |||
Student First Technologies BusinessSupport Student First Technologies, a company that administers state tax credit scholarship programs, submitted comments regardi | · | · | |||
Support for Catholic Schools, Inc AdvocacySupport Support for Catholic Schools, a Kansas-based 501(c)3, supports the implementation of the Federal Scholarship Tax Credit. | · | · | · | · | |
Teach For America AdvocacySupport Teach For America supports the proposed federal scholarship tax credit program but urges that the regulations allow scho | · | · | · | · | |
Tennessee Association of Independent Schools Trade associationSupport The Tennessee Association of Independent Schools supports the federal scholarship tax credit (FSTC) and provides specifi | · | · | · | ||
Tennessee SGO AdvocacySupport Tennessee SGO, a newly formed entity to administer the EFTC in Tennessee, supports the proposed action and the Treasury | · | · | · | · | |
Texas Catholic Conference of Bishops AdvocacySupport The Texas Catholic Conference of Bishops submitted recommendations to clarify the Federal Scholarship Tax Credit (FSTC) | · | · | · | · | · |
The Angel Scholarship Fund (Scholarship Granting Organization of the Catholic Community Foundation) AdvocacySupport The Scholarship Granting Organization of the Catholic Community Foundation (Angel Scholarship Fund) supports the propose | · | · | |||
The Arc of the United States AdvocacyOppose The Arc of the United States, a national organization advocating for individuals with intellectual and developmental dis | · | · | · | · | |
The Cardinal Newman Society AdvocacySupport The Cardinal Newman Society supports the new federal tax credit scholarship program but argues that the final regulation | · | · | · | ||
The Lutheran Church - Missouri Synod Office of School Ministry AdvocacySupport The Lutheran Church – Missouri Synod (LCMS) supports the Federal Scholarship Tax Credit (FSTC) but urges the Treasury to | · | · | |||
The National Parents Union AdvocacySupport The National Parents Union supports the proposed tax credit scholarship program but urges the Treasury to ensure it prio | · | · | · | ||
The National SGO AdvocacySupport The National SGO, a newly created non-profit scholarship granting organization, provides comments on proposed regulation | · | · | · | · | · |
The North Dakota Catholic Conference AdvocacySupport The North Dakota Catholic Conference (NDCC) supports the Federal Scholarship Tax Credit (FSTC) program but requests spec | · | · | · | · | |
The Parents' Campaign Research & Education Fund AdvocacyOppose The Parents’ Campaign Research & Education Fund (TPCREF), an alliance of Mississippi parents and community leaders, oppo | · | · | · | · | |
U.S. Conference of Catholic Bishops AdvocacySupport The U.S. | · | · | |||
Union of Orthodox Jewish Congregations of America, via its policy arms OU Advocacy and Teach Coalition AdvocacySupport The Union of Orthodox Jewish Congregations of America, through its advocacy arms OU Advocacy and Teach Coalition, suppor | · | · | · | · | |
Vital Software BusinessSupport Vital Software, a company in formation that provides software for Scholarship Granting Organizations (SGOs), supports th | · | · | · | ||
Washington Federation of Independent Schools AdvocacySupport The Washington Federation of Independent Schools (WFIS) submitted comments requesting specific clarifications and interp | · | · | |||
Wisconsin Independent Charter School Advocates AdvocacySupport The Wisconsin Independent Charter School Advocates (WICSA) supports the implementation of the Section 25F tax credit and | · | · | · | · | · |
Wisconsin Institute for Law & Liberty AdvocacySupport The Wisconsin Institute for Law & Liberty (WILL) supports the implementation of the federal scholarship tax credit but a | · | · | · | ||
yes. every kid. AdvocacySupport The organization "yes. | · | · | · | · | |
YMCA of the USA AdvocacySupport The YMCA of the USA supports the new tax credit for scholarship granting organizations and recommends specific regulator | · | · | · | · | · |
21 organization-typed comments could not be identified.
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
- Jan 7, 2026George W. Bush InstituteSupportAdvocacy📎 Attachment
The George W. Bush Institute supports the new federal tax credit for scholarship-granting organizations and advocates for a regulatory framework that prioritizes students with high financial need and disabilities. They request clear guidance on state participation timelines, income verification standards, and oversight mechanisms to ensure the program's effective implementation.
Read comment → - Dec 30, 2025Jewish Federations of North AmericaSupportAdvocacy📎 Attachment
The Jewish Federations of North America supports the creation of the individual tax credit for scholarship granting organizations (SGOs) as a means to increase affordability and access to faith-based and community-based education. They provide specific recommendations to simplify administrative burdens, clarify credit calculations for joint filers, and ensure that the regulations allow for inclusive and non-discriminatory scholarship distribution.
Read comment → - Dec 30, 2025Well Planned DaySupportOther📎 Attachment
The commenter provides detailed technical feedback on the implementation and enforcement of IRC §25F, focusing on operational risks such as jurisdictional traceability, aggregated accounting, and donor designation integrity. They argue for clear guidance that establishes enforceable boundaries and verifiable recordkeeping to ensure the program's durability and integrity across different states.
Read comment → - Dec 26, 2025Alabama Opportunity Scholarship FundSupportAdvocacy📎 Attachment
The Alabama Opportunity Scholarship Fund, an organization representing families and schools, supports the proposed action but urges the Treasury to adopt specific favorable interpretations. They advocate for allowing multiple forms of income verification for eligibility, allowing donors to designate specific states/schools, and excluding non-program funds from the 90% income rule to ensure SGOs can remain viable.
Read comment → - Dec 26, 2025EdChoiceSupportAdvocacy📎 Attachment
EdChoice, a nonpartisan educational choice organization, supports the implementation of the Section 25F federal tax credit for scholarship granting organizations (SGOs). They argue for streamlined regulations that avoid overly burdensome certification requirements, allow for flexible definitions of "located" and "qualified expenditures," and ensure that the credit does not create barriers for small or religious educational providers.
Read comment → - Dec 26, 2025IFPC Legal CenterSupportAdvocacy📎 Attachment
The Idaho Family Policy Center Legal Center supports the proposed tax credit but argues that the IRS should interpret "taxpayer" to allow married couples filing jointly to claim two individual credits rather than one. They also advocate for rules that prevent states from using their discretion to discriminate against religious scholarship granting organizations.
Read comment → - Dec 26, 2025Alaska Afterschool NetworkSupportAdvocacy📎 Attachment
The Alaska Afterschool Network supports the implementation of the new tax credit for scholarship granting organizations and provides recommendations to maximize parent choice. They argue for inclusive definitions of "extended day" and summer learning programs, the ability for organizations to specialize in specific scholarship types, and simplified accounting for 501(c)(3) organizations.
Read comment → - Dec 26, 2025New Jersey Council for American Private EducationSupportAdvocacy📎 Attachment
The New Jersey Council for American Private Education (NJCAPE) submitted comments providing specific recommendations to clarify and refine the Treasury's rulemaking on the Federal Scholarship Tax Credit (FSTC). They argue for interpretations that prevent a "marriage penalty" for donors, protect religious school autonomy, and ensure that state-level requirements do not create undue burdens or discriminatory barriers for scholarship granting organizations.
Read comment → - Dec 26, 2025Alabama Expanded Learning Alliance (AELA)SupportAdvocacy📎 Attachment
The Alabama Expanded Learning Alliance supports the new federal tax credit for scholarship granting organizations and advocates for clear definitions that include community-based, faith-based, and for-profit "extended day" and summer learning programs. They also recommend allowing for separate accounting structures for 501(c)(3) organizations and ensuring states can establish their own policies to meet specific educational goals.
Read comment → - Dec 26, 2025Wisconsin Independent Charter School AdvocatesSupportAdvocacy📎 Attachment
The Wisconsin Independent Charter School Advocates (WICSA) supports the implementation of the Section 25F tax credit and proposes specific rules to maximize its impact for public and charter schools. They advocate for multi-SGO stacking flexibility, lower reporting thresholds for small grants, the use of existing income verification systems, multi-year averaging of administrative costs, and clear guidelines for public school expenditures.
Read comment →
