Summary

Creates a new tax exclusion that lets sellers avoid reporting gain when they sell certain property interests to qualified conservation organizations if the sale is for purposes of the Department of Defense Readiness and Environmental Protection Integration (REPI) program. The exclusion applies to full ownership interests, remainder interests, and perpetual use restrictions (and can allow retained mineral interests if no surface-mining access), but it denies the exclusion for pass-through entities that acquired the interest by purchase within the prior three years (with a family-partnership exception). The rule is effective for taxable years beginning after enactment.

• Creates IRC section 139J to exclude gain on sales to qualified organizations for REPI land protection.
• Applies to full ownership, remainder interests, and perpetual use restrictions; retained mineral interests can be allowed if no surface mining.
• Limits the exclusion for pass-through entities that purchased the interest within the prior three years (anti-flip rule).
• Includes an exception for family partnerships or family-held pass-through entities.
• Defines qualified organizations by reference to the charitable conservation rules in IRC section 170(h)(3).
• Ties the exclusion specifically to transactions made for Department of Defense REPI purposes.
• Effective for taxable years beginning after enactment; requires Treasury/IRS guidance for pass-through details.
• Does not appropriate funds or change DoD program authorities; it modifies tax treatment only.