credits for certain small projects (a) In general Section 47(e) of the Internal Revenue Code of 1986, as amended by section 2, is amended by adding at the end the following new subsection: (4) Transfer of smaller project credit (A) In general Subject to subparagraph (B) and such regulations or other guidance as the Secretary may provide, the taxpayer may transfer all or a portion of the credit allowable to the taxpayer under subsection (a) for a smaller project. (B) Certification (i) In general A transfer under subparagraph (A) shall be accompanied by a certificate which includes— (I) the certification for the certified historic structure referred to in subsection (c)(3), (II) the taxpayer’s name, address, tax identification number, date of project completion, and the amount of credit being transferred, (III) the transferee’s name, address, tax identification number, and the amount of credit being transferred, and (IV) such other information as may be required by the Secretary. (ii) Transferability of certificate A certificate issued under this section to a taxpayer shall be transferable to any other taxpayer, except that a certificate may not be transferred more than once. (C) Tax treatment relating to certificate (i) Disallowance of deduction No deduction shall be allowed for the amount of consideration paid or incurred by the transferee. (ii) Allowance of credit The amount of credit transferred under subparagraph (A)— (I) shall not be allowed to the transferor for any taxable year, and (II) shall be allowable to the transferee as a credit under this section for the taxable year of the transferee in which such credit is transferred. (D) Recapture and other special rules The taxpayer who claims a credit under this section by reason of a transfer of an amount of credit under subparagraph (A) with respect to a smaller project shall be treated as the taxpayer with respect to the smaller project for purposes of section 50. (E) Information reporting The transferor and the transferee shall each make such reports