H.R. 4115

119th CONGRESS 1st Session

To amend the Internal Revenue Code of 1986 to exclude certain discharges of indebtedness secured by real property from income.

IN THE HOUSE OF REPRESENTATIVES · June 24, 2025 · Sponsor: Ms. Tenney · Committee: Committee on Ways and Means

Table of contents

• H.R. 4115
  • SEC. 1. Short title
  • SEC. 2. Excluding discharge of commercial or retail indebtedness from income

SEC. 1. Short title

• This Act may be cited as the , or the .

SEC. 2. Excluding discharge of commercial or retail indebtedness from income

• (a) In general
  • of the Internal Revenue Code of 1986 is amended by striking at the end of subparagraph (D), by striking the period at the end of subparagraph (E)(ii) and inserting , or, and by adding at the end the following new subparagraph: Section 108(a)(1)
    • the indebtedness discharged is qualified commercial or retail indebtedness.
• (b) Commercial or retail indebtedness defined
  • Section 108 of such code is amended by adding at the end the following new subsection:
    • (j) Commercial or retail indebtedness defined
      • For purposes of this section:
      • (1) In general
        • The term qualified means indebtedness which is— commercial or retail indebtedness
          • incurred or assumed by the taxpayer before March 1, 2023,
          • discharged during the period beginning on December 31, 2023, and ending on January 1, 2028, and
          • secured directly or indirectly by specified real property of the taxpayer at all times after such indebtedness was so incurred or assumed and before such discharge.
      • (2) Specified real property
        • The term means real property which is— specified real property
          • used in a trade or business of the taxpayer,
          • not described in section 168(b)(3)(B), and
          • not described in section 144(c)(6)(B).
• (c) Coordination of exclusions
  • Section 108(a)(2)(A) of such Code is amended by striking and (E)and inserting (E), and (F).
  • is amended— Section 108(a)(2)(B)
    • in the header, by striking and inserting , and
    • by striking and (D)and inserting (D), and (F).
• (d) Reduction of tax attributes
  • is amended by striking or (C)and inserting (C), or (F). Section 108(b)(1)
• (e) Effective date
  • The amendments made by this section apply to discharges of indebtedness occurring on or after December 31, 2023.