Summary

Disallows certain tax benefits and blocks some federal sales and financing to large institutional owners of residential property, then directs estimated tax savings to HUD for homebuyer and housing programs. It also expands antitrust reporting and creates a presumption against large-scale acquisitions of residential properties over a 30% market share. The bill targets institutional investment entities and aggregated “large owners” by denying interest and depreciation deductions on many rental properties they control (with narrow exceptions for nonprofits, new construction by builders, rehabilitation, and federally subsidized affordable housing). It forbids federal agencies and government-sponsored enterprises from selling or financing federally backed loans or covered residential property to these investors, sets aside most estimated savings for the HOME program and a homebuyer assistance fund starting FY2026, and requires additional merger reporting and an antitrust presumption for large housing acquisitions.

Key Points

• Denies interest and depreciation tax deductions for residential rental property majority‑owned by institutional investors or aggregated large owners, with targeted exemptions for nonprofits, new construction by builders, substantial rehab, and federally subsidized affordable housing.
• Bars federal agencies and GSEs from selling or financing federally backed mortgage loans or covered residential property to such institutional investors or large owners, with narrow exceptions for affordability‑restricted construction/rehab financing.
• Requires Treasury to estimate and transfer annual tax‑savings beginning FY2026: 80% goes to the HOME program (with set priorities) and 20% funds a homebuyer assistance grant program for qualified buyers.
• Creates a new definition of “qualified homebuyer” (income caps tied to AMI and first‑time/first‑generation rules) to target grant assistance and program benefits.
• Expands merger/antitrust review for housing transactions, rescinds prior exemptions, and establishes a presumption that acquisitions raising market share above 30% are anticompetitive.
• Adds reporting, regulatory, and anti‑avoidance directives to Treasury, HUD, FTC, and DOJ to implement the tax, programmatic, and antitrust changes.
• Amendments to tax capitalization and depreciation rules prevent taxpayers from converting disallowed interest into capitalized costs.
• Many routine acquisitions and loans in place before enactment are grandfathered; most substantive changes take effect after enactment or for taxable years beginning after enactment.

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