Sponsors (18)
The bill encourages voluntary conservation sales near military installations—improving base protection and giving sellers tax relief and the ability to retain mineral rights—but does so at the cost of reduced federal revenue and with rules that limit or unevenly allocate benefits for some buyers.
Owners of land sold as conservation or perpetual-use interests to REPI-approved organizations can exclude the gain from taxable income, lowering their federal tax bill when they sell such interests.
The law makes it easier for the Department of Defense to secure voluntary buffer lands around military installations by encouraging these conservation transactions, helping protect military readiness and nearby communities from incompatible development.
Sellers can keep underlying mineral rights (provided no surface access for mining) without losing the tax exclusion, allowing mineral owners to preserve economic interests while still participating in conservation sales.
The exclusion reduces federal tax revenue, which could increase the deficit or require spending cuts or other revenue increases to offset the loss.
Pass-through entities that purchased land within the prior three years are barred from using the exclusion, complicating transactions and potentially deterring some recent buyers from participating in REPI sales.
A family-partnership exception could let tax-favored conservation sales remain within families, producing uneven tax benefits that favor family-owned entities over unrelated buyers.
Based on analysis of 2 sections of legislative text.
Excludes gains from sales of qualifying property interests to qualified organizations for DoD REPI purposes, with a 3‑year anti‑flip rule for pass‑throughs.
Official title: 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 February 6, 2025 by Gregory Francis Murphy · Last progress February 6, 2025
Excludes from taxable income gains when a taxpayer sells certain real property interests to qualified organizations for purposes of the Department of Defense Readiness and Environmental Protection Integration (REPI) program. It defines which real property interests and organizations qualify, adds an anti‑flip rule for pass‑through entities, and applies prospectively to taxable years beginning after enactment. The measure creates a new Internal Revenue Code section that lets landowners who sell qualifying interests for REPI purposes avoid reporting the gain, but denies the exclusion if a pass‑through entity acquired the interest by purchase within the prior three years (with a family partnership exception). The bill also updates the Code table of sections accordingly.