Adds new section 139J to Part III of subchapter B of chapter 1 of the Internal Revenue Code, providing that gross income does not include amounts provided to a dependent pursuant to a scholarship for qualified elementary or secondary education expenses of an eligible student provided by a scholarship granting organization and incorporating definitions by reference to section 25F(c) for the terms 'qualified elementary or secondary education expense', 'eligible student', and 'scholarship granting organization'.

Amends the table of sections for Part III of subchapter B by inserting a new item for section 139J before the item relating to section 140.

Adds new section 25F to Subpart A of Part IV of Subchapter A (chapter 1) establishing an individual tax credit for qualified contributions to scholarship granting organizations, including limits, definitions (eligible student, qualified contribution, qualified elementary or secondary education expense, scholarship granting organization), organizational requirements, denial of double benefit, and carryforward rules.

Amends the cross-reference list in section 25(e)(1)(C) to add the new section 25F to the list of sections referenced.

Inserts a new table entry after the item relating to section 25E to list the newly added section 25F.

Adds new section 45BB in Subpart D of Part IV of Subchapter A (chapter 1) establishing a corporate tax credit for qualified contributions to scholarship granting organizations (credit amount limited to 5 percent of taxable income, denial of double benefit, application of volume cap, cross-reference to section 25F for the definition of qualified contributions).

Amends section 38(b) to add a new paragraph (42) recognizing the education scholarship credit determined under section 45BB(a) for purposes of the general business tax credit rules.

Adds a new item at the end of the table of sections for Subpart D to list the newly added section 45BB.

Adds a new subchapter at the end of Chapter 42 (chapter-level addition) addressing failures of scholarship granting organizations to make distributions (text of new subchapter inserted at end of chapter).

Adds a new item to the table of subchapters for Chapter 42 to reflect the newly added subchapter regarding scholarship granting organizations.