Code of 1986, as added by section 2, is amended by adding at the end the following new paragraph: (4) Transfer of small project credit (A) In general Subject to subparagraph (B) and such regulations or other guidance as the Secretary may provide, the taxpayer may transfer to any other taxpayer all or a portion of the credit allowable to the taxpayer under subsection (a) for a small project. (B) Certification A transfer under subparagraph (A) shall be accompanied by a certificate which includes— (i) the certification for the certified historic structure, (ii) the taxpayer’s name, address, and tax identification number, (iii) the transferee’s name, address, and tax identification number, (iv) the date of project completion and the amount of credit being transferred, and (v) such other information as may be required by the Secretary. (C) Credit may only be transferred once A credit transferred under subparagraph (A) is not transferable by the transferee to any other taxpayer. (D) Tax treatment of transfer (i) Disallowance of deduction No deduction shall be allowed for any amount of consideration paid or incurred by the transferee in return for the transfer of any credit under this paragraph. (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. (E) Recapture and other special rules For purposes of section 50, the transferee of a credit with respect to a smaller project under this paragraph shall be treated as the taxpayer with respect to the smaller project. (F) Information reporting The transferor and the transferee shall each make such reports regarding the transfer of an amount of credit under subparagraph (A), and containing such information, as the Secretary may require. The reports required by this subparagraph shall be filed at such time and in such manner as may be