[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 1083 Introduced in House (IH)]
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119th CONGRESS
1st Session
H. R. 1083
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.
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IN THE HOUSE OF REPRESENTATIVES
February 6, 2025
Mr. Murphy (for himself and Mr. Panetta) introduced the following bill;
which was referred to the Committee on Ways and Means
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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.
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