Excludes certain debt instruments held by specified insurance companies from the definition of "capital assets," changing how gains and losses on those instruments are taxed. It also extends the period to use net capital loss carryovers to 10 years for losses that result from foreign expropriation or losses incurred by those same insurance companies.

Both changes take effect for items acquired or losses arising in taxable years beginning after December 31, 2025, and generally aim to change timing and character of tax treatment for insurers and certain foreign-loss events.