The bill encourages voluntary conservation sales to support military installation buffers and reduces tax burdens for participating landowners, but it lowers federal revenue and creates eligibility limits and potential unequal tax advantages for certain entities.
Landowners selling conservation or perpetual-use interests to REPI-approved organizations can exclude the gain from federal taxable income, lowering their tax bills and making voluntary transactions more attractive — which helps the Department of Defense secure buffer lands that protect nearby communities and military readiness.
Landowners who sell conservation interests can retain subsurface/mineral interests (provided there is no surface mining access) without losing the tax exclusion, preserving mineral owners' economic value while enabling conservation sales.
All taxpayers face reduced federal tax revenue because the exclusion lowers collections, which could increase the deficit or require spending cuts or revenue offsets elsewhere.
Pass-through entities that purchased land within the prior three years cannot use the exclusion, which may deter some transactions, complicate deals, and disadvantage certain small-business owners.
Family-partnership exceptions may allow tax-favored transactions to remain inside families, creating uneven tax benefits that favor family-owned entities over unrelated buyers.
Based on analysis of 2 sections of legislative text.
Excludes gain from sale of qualifying real property interests to eligible organizations for DoD REPI transactions, with a 3-year anti-flip rule for pass-throughs.
Creates a new federal tax exclusion that lets sellers exclude capital gain when they sell qualifying land interests to eligible organizations for transactions under the Department of Defense Readiness and Environmental Protection Integration (REPI) program. The change defines what counts as a qualifying real property interest and a qualified buyer, adds a 3-year anti-flip rule for pass-through entities (with a family partnership exception), and applies to taxable years beginning after enactment.
Introduced February 6, 2025 by Gregory Francis Murphy · Last progress February 6, 2025