H.R. 1083

119th CONGRESS 1st Session

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.

IN THE HOUSE OF REPRESENTATIVES · February 6, 2025 · Sponsor: Mr. Murphy · Committee: Committee on Ways and Means

Table of contents

• H.R. 1083
  • Sec. 139J. Gain from sale of qualified real property interest for purposes related to the readiness and environmental protection integration program.

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—
    • The term qualified organization has the meaning given such term by section 170(h)(3).
    • 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.