PROPOSED FEDERAL CREDIT

A federal film credit, run on your budget.

The Motion Picture, Television, and Entertainment Revitalization Act, introduced in both chambers on September 24, 2026, would add a transferable 20% federal credit on US labor, rising to 30% with bonuses. The House and Senate texts are nearly identical. Switch between them to see where they aren't.

Proposed legislation. Nothing here can be claimed yet.

H.R. (Moran) · Rep. Nathaniel Moran (R-TX-1)

What are you claiming for?

A feature, a pilot, or a season of 4+ episodes.

Total production cost

Must exceed $1,000,000.

US labor (qualified compensation)

Cast, crew, directors, producers and writers, for work done in the US, including prep and post. Contractors count. Participations and residuals do not.

Principal photography days in the US

100%needs 75% ✓

Animation counts the cost of US animation work instead.

Photography starts

Completes

Bonuses, +5 points each, up to 30%

Rural opportunity zone or disaster area§45BB(d)(2): 30% or more of principal photography days in a rural qualified opportunity zone, or in a federally declared disaster area within 5 years of the declaration.Independent producer§45BB(d)(3): the taxpayer is not publicly traded and not majority-owned by a publicly traded company, with related companies aggregated.Multi-state producer§45BB(d)(4): in 10+ states over the year and the 12 months before, a production shot at least 50% there, with $10M+ of qualified compensation there.

Increased domestic productionFor a company that shot abroad and is bringing productions home. The test is company-wide, and this is where the two bills differ most.

Sale price if you transfer the credit

90¢ per $1our assumption, not the bill's

The credit is transferable under IRC §6418, like the clean-energy credits. Those trade at a discount, and this one would too.

Estimated federal credit · House bill

$3,000,000

25% of $12,000,000 in US labor

About $2,700,000 in cash if sold at 90¢.

Under the Senate bill: $3,000,000 at 25%. The same for this project.

How it adds up

Base rate20%
Independent producer+5%
Rate25%

Qualifying tests

Passes: Total cost over $1M§45BB(b)(1)(E): the production's total cost must exceed $1,000,000.
Passes: 75% of principal photography days in the US§45BB(b)(1)(F). Animation is measured by the cost of US animation work, (b)(3).
Passes: Starts after 2026Effective date, sec. 2(e): productions whose principal photography commences in tax years beginning after Dec 31, 2026.
Passes: Completes no earlier than it startsThe credit is claimed in the tax year the production completes, §45BB(b)(1)(D) and (g)(1).

Proposed legislation, not law. The credit reduces the production's tax basis, §45BB(g)(4). It is a general business credit, so it offsets tax rather than paying out, unless it is sold. The bill does not reduce it for state incentives you also claim. Calendar-year taxpayer assumed.

HOUSE VS SENATE

Where the two texts differ.

We compared the two introduced texts word by word. The base rate, the 30% cap, the qualifying tests, the zone, independent and multi-state bonuses, and transferability are the same in both. These are the only substantive differences.

Provision	Senate	House	Why it matters
When it starts	Productions “commencing” in tax years beginning after Dec 31, 2026. “Commencing” is not defined.	Productions whose principal photography commences in tax years beginning after Dec 31, 2026.	The House ties eligibility to a defined event. Under the Senate text a show in pre-production in 2026 could be argued either way.
Domestic-increase bonus: start year	The first tax year beginning after enactment.	The first tax year beginning after Dec 31, 2026, whenever the bill is enacted.	A late enactment pushes the Senate schedule back; the House schedule is fixed.
Domestic-increase bonus: threshold	No percentage for the start year; then 30%, 40%, and 50% for years three to five of the foreign base. After year five the percentage is 0.	30% in the start year, 40% the next, 50% every year after. No end date.	The Senate bonus cannot be earned in the first year. After year five a 0% threshold arguably lets any taxpayer with a foreign base qualify just by not shrinking. That reads like a drafting slip meant as a sunset, and Treasury or a markup would have to settle it.
VFX and post projects in the increase count	Count toward the number of domestic productions.	Excluded from the count, so only full productions move the needle.	A studio could not reach the House threshold by buying US post work on foreign shoots.
Multi-state bonus scope	Applies to “all qualified film or television productions” for the year.	Applies to all qualified productions “completed in such taxable year.”	Little in practice: a production earns the credit only in the year it completes, under both texts.

Drafting errors in both texts

The VFX and post-production rules define “independent producer” by pointing to §45BB(d)(4)(B), which is the multi-state producer definition. The independent-producer definition is (d)(3)(B). We apply (d)(3)(B), which is plainly what is meant.
The disaster-area test runs “5-year period beginning on the of the date” the President declared assistance warranted, with a word missing. We read it as five years from that date.
The Senate text labels the post-production project definition “qualified visual effects production”. The House text corrects it to “qualified post-production project”.

Sources

Figures on this page come from the introduced bill text (new IRC §45BB), read against the sponsors' section-by-section summary. Bill numbers were not yet assigned when we published.

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