REPI Sales Gain Exclusion

Full Title:
Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025

Summary#

This bill adds a new section to the Internal Revenue Code (section 139J). It says that gain (profit) from the sale of certain real property interests to qualified organizations for REPI purposes is not included in gross income. "Qualified real property interest" can mean the seller's entire ownership, a remainder interest, or a perpetual restriction on use created under state law. Mineral interests can still qualify if any retained mineral rights do not allow surface mining access. "Qualified organization" is the term used in section 170(h)(3). A sale counts as for REPI purposes only if it is done under the Readiness and Environmental Protection Integration (REPI) authority in 10 U.S.C. 2684a. The bill limits the exclusion for sales by pass-through entities that bought the property within 3 years, with an exception for family partnerships or similarly treated family pass-through entities. It adds a clerical entry to the tax code table of sections and applies to taxable years beginning after enactment. The bill was introduced on February 6, 2025, and was referred to the House Committee on Ways and Means.

What it means for you#

  • If you sell a qualifying interest in land to a REPI-eligible organization under the REPI program, you may exclude the gain from your gross income for federal tax purposes.
  • If the seller is a pass-through entity (for example, a partnership or S corporation) that itself bought the same property by sale within the prior 3 years, the exclusion does not apply.
  • The 3-year restriction does not apply to family partnerships or similar family pass-through entities when substantially all partnership interests are held by an individual and that person's family, as defined in the tax code.
  • The rule only applies to sales done under REPI authority and to tax years starting after the law would take effect.

Expenses#

No publicly available information on estimated federal revenue effects, costs, or budgetary impacts is included in the bill text or the provided metadata.

Proponents' View#

No publicly available information in the bill text or provided metadata describes supporters' stated reasons or arguments for the bill.

Opponents' View#

No publicly available information in the bill text or provided metadata describes opponents' stated reasons or arguments against the bill.