Congressional Legislation · bill 119s439 · built from our database

Both sides have signed this (Bill Ranking)

Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025

S. 439 · 119th Congress (2025-2026)

S. 439119TH CONGRESSINTRODUCED 02/06/2025SEN. BUDDR-NC · SPONSORLeft: no (Sponsor Ranking)Lean left: no (Sponsor Ranking)Center: no (Sponsor Ranking)Lean right: no (Sponsor Ranking)Right: DW-NOMINATE +0.63 (Sponsor Ranking)RIGHT(SPONSOR RANKING)TAXATION

6 members · Left 2 · Center 1 · Right 3 (Bill Ranking)

SponsorSen. Budd, Ted (R-NC) (Introduced 02/06/2025)
Sponsor Voting RecordRight · DW-NOMINATE +0.63 · measured from every roll-call vote this member has cast (voteview.com) (Sponsor Ranking)
Support
LLLCLRR

support across the spectrum: 6 members signed on (Bill Ranking) this bill: sponsor + current cosponsors, each once

CommitteesSenate - Finance Committee; Senate - Finance Committee
Latest Action02/06/2025 Read twice and referred to the Committee on Finance.
Roll Call VotesThere have been no roll call votes
Sourceview on congress.gov →
IntroducedPassed HousePassed SenateResolving DifferencesTo PresidentBecame Law

Summary (1)

Introduced in Senate (02/06/2025)

Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025 

This bill excludes the gain from the sale of a qualified real property interest under the Readiness and Environmental Protection Integration (REPI) Program from gross income for federal tax purposes. (Some limitations apply.)

As background, the REPI Program supports cost-sharing agreements between the Armed Forces, other federal agencies, state and local governments, and certain private organizations to address land use near military installations, address environmental restrictions that limit military activities, and increase military installation resilience.

Under the bill, the exclusion from gross income applies to gain from the sale of a real property interest (pursuant to an agreement under the REPI Program) to

  • a state or U.S. possession (or a political subdivision of a state or U.S. possession) or the District of Columbia;
  • the United States;
  • certain corporations, trusts, community chest, funds, or foundations; or
  • certain charitable organizations.

Further, under the bill, the real property interest that is sold may be (1) the entire interest in the real property, (2) a remainder interest in the real property, or (3) a restriction on the use of the real property (e.g., easement) that is granted in perpetuity and created under state law.

However, the bill limits such exclusion from gross income for a partnership or other pass-through entity (other than a family partnership or family pass-through entity) to gain from the sale of a real property interest that is held for at least three years.

Text (1)

Introduced in Senate (IS)

119 S439 IS: Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025 U.S. Senate 2025-02-06 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. II119th CONGRESS1st SessionS. 439IN THE SENATE OF THE UNITED STATESFebruary 6 (legislative day, February 5), 2025Mr. Budd (for himself and Mr. Kaine) introduced the following bill; which was read twice and referred to the Committee on FinanceA BILLTo 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.1.Short titleThis Act may be cited as the Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025.2.Exclusion of gain from sale of qualified real property interests acquired for purposes related to the readiness and environmental protection integration program(a)In generalPart 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:139J.Gain from sale of qualified real property interest for purposes related to the readiness and environmental protection integration program(a)In generalGross income shall not include any gain from the sale of qualified real property interest to a qualified organization for REPI purposes.(b)DefinitionsFor purposes of this section—(1)Qualified real property interest(A)In generalThe 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 interestsAn 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 organizationThe term qualified organization has the meaning given such term by section 170(h)(3).(3)REPI purposesA 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 generalIn 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 generalParagraph (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 familyFor 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 entitiesExcept 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 amendmentThe 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 dateThe amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.

The bill's own words, from our database (synced from the GPO BILLS XML); paragraph breaks added at the bill's section boundaries, nothing else changed.

All Actions (2)

DateChamberAll Actions
02/06/2025Library of CongressIntroduced in Senate
02/06/2025SenateRead twice and referred to the Committee on Finance.

Titles (3)

Title TypeTitle
Display TitleIncentivizing Readiness and Environmental Protection Integration Sales Act of 2025
Short Title(s) as IntroducedIncentivizing Readiness and Environmental Protection Integration Sales Act of 2025
Official Title as IntroducedA 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.

Amendments (0)

There are no amendments to this bill.

Cosponsors (5)

* = Original cosponsor

Committees (2)

CommitteeActivity
Senate - Finance Committee02/06/2025 Referred To
Senate - Finance Committee02/06/2025 Referred To

Related Bills (1)

Subjects (0)

Policy Area: Taxation

No legislative subjects have been assigned yet.

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