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Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025

To amend the Internal Revenue Code of 1986 to exclude from gross income gain from the sale of qualified real property interests acquired under the authority of the Readiness and Environmental Protection Integration (REPI) program administered by the Department of Defense pursuant to section 2684a of title 10, United States Code, and for other purposes.

Introduced Feb 6, 2025

Latest action (Feb 6, 2025) Read twice and referred to the Committee on Finance.

Policy area
Issues
Climate & EnergyEconomy & Taxes

Summary

This bill amends the Internal Revenue Code to exclude from taxable income any gain from selling qualified real property interests to qualified organizations for purposes related to the Department of Defense's Readiness and Environmental Protection Integration (REPI) program. Qualified interests include full property ownership, remainder interests, and perpetual use restrictions, and may include mineral interests if not accessed through surface mining. The property must be sold to organizations defined as qualified under existing tax law and the sale must be pursuant to the REPI program administered by the Department of Defense. The bill limits the tax exclusion for pass-through entities that acquired the property within 3 years of selling it, except for family partnerships where substantially all interests are held by an individual and family members. The provisions apply to taxable years beginning after the bill's enactment.

AI-generated plain-language summary of the bill text — neutral, and may be imperfect. See the full text below for the exact wording.

Sponsor (1)

Actions (2)

  1. Feb 6, 2025 Read twice and referred to the Committee on Finance. · senate
  2. Feb 6, 2025 Introduced in Senate

Similar bills (6)

Bills with similar text or summary — includes reintroductions across Congresses. Ranked by semantic similarity of the bill text (computed locally); a neutral discovery aid, not a claim the bills are duplicates.

Full text

IN THE SENATE OF THE UNITED STATES

February 6 (legislative day, February 5), 2025

Mr. Budd (for himself and Mr. Kaine) introduced the following bill; which was read twice and referred to the Committee on Finance

A BILL

To amend the Internal Revenue Code of 1986 to exclude from gross income gain from the sale of qualified real property interests acquired under the authority of the Readiness and Environmental Protection Integration (REPI) program administered by the Department of Defense pursuant to section 2684a of title 10, United States Code, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the “Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025”.

SEC. 2. EXCLUSION OF GAIN FROM SALE OF QUALIFIED REAL PROPERTY INTERESTS ACQUIRED FOR PURPOSES RELATED TO THE READINESS AND ENVIRONMENTAL PROTECTION INTEGRATION PROGRAM.

(a) In General.—Part III of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 139I the following new section:

“SEC. 139J. GAIN FROM SALE OF QUALIFIED REAL PROPERTY INTEREST FOR PURPOSES RELATED TO THE READINESS AND ENVIRONMENTAL PROTECTION INTEGRATION PROGRAM.

“(a) In General.—Gross income shall not include any gain from the sale of qualified real property interest to a qualified organization for REPI purposes.

“(b) Definitions.—For purposes of this section—

“(1) Qualified real property interest.—

“(A) In general.—The term ‘qualified real property interest’ means any of the following interests in real property:

“(i) The entire interest of the taxpayer.

“(ii) A remainder interest.

“(iii) A restriction (granted in perpetuity and created pursuant to State real property law) on the use which may be made of the real property.

“(B) Special rule for mineral interests.—An interest in real property shall not fail to be treated as a qualified real property interest solely by reason of a retention of a qualified mineral interest (as defined in section 170(h)(6)), but only if the right to access such mineral interest is not accomplished by any surface mining method.

“(2) Qualified organization.—The term ‘qualified organization’ has the meaning given such term by section 170(h)(3).

“(3) REPI purposes.—A sale of qualified real property interest shall be treated as being for REPI purposes if such sale is pursuant to the authority of the Readiness and Environmental Protection Integration (REPI) program administered by the Department of Defense under section 2684a of title 10, United States Code.

“(c) Limitation.—

“(1) In general.—In the case of a pass-through entity, no amount shall be excluded from gross income under subsection (a) with respect to a sale if such entity acquired the qualified real property interest by sale within 3 years of the date of the sale described in subsection (a).

“(2) Exception for family partnerships or family pass- through entities.—

“(A) In general.—Paragraph (1) shall not apply with respect to any sale made by any partnership if substantially all of the partnership interests in such partnership are held, directly or indirectly, by an individual and members of the family of such individual.

“(B) Members of the family.—For purposes of this paragraph, the term ‘members of the family’ means, with respect to any individual—

“(i) the spouse of such individual, and

“(ii) any individual who bears a relationship to such individual which is described in subparagraphs (A) through (G) of section 152(d)(2).

“(C) Application to other pass-through entities.— Except as may be otherwise provided by the Secretary, the rules of this paragraph shall apply to S corporations and other pass-through entities in the same manner as such rules apply to partnerships.”.

(b) Clerical Amendment.—The table of sections for part III of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to section 139I the following new item:

“Sec. 139J. Gain from sale of qualified real property interest for purposes related to the readiness and environmental protection integration program.”.

(c) Effective Date.—The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. <all>

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