H.R. 2547

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2547 Introduced in House (IH)]

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119th CONGRESS
1st Session
H. R. 2547

To amend the Internal Revenue Code of 1986 to exclude debt held by 
certain insurance companies from capital assets and to extend capital 
loss carryovers for such companies from 5 years to 10 years.

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IN THE HOUSE OF REPRESENTATIVES

April 1, 2025

Mr. Feenstra (for himself, Ms. Sewell, and Mr. Flood) introduced the 
following bill; which was referred to the Committee on Ways and Means

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A BILL

To amend the Internal Revenue Code of 1986 to exclude debt held by 
certain insurance companies from capital assets and to extend capital 
loss carryovers for such companies from 5 years to 10 years.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the ``Secure Family Futures Act of 2025''.

SEC. 2. DEBT NOT TREATED AS CAPITAL ASSET FOR APPLICABLE INSURANCE 
COMPANIES.

(a) Exclusion From Capital Assets.--Section 1221(a) of the Internal 
Revenue Code of 1986 is amended by striking ``or'' at the end of 
paragraph (7), by striking the period at the end of paragraph (8) and 
inserting ``; or'', and by adding at the end the following new 
paragraph:
``(9) any note, bond, debenture, or other evidence of 
indebtedness held by an applicable insurance company.''.
(b) Applicable Insurance Company Defined.--Section 1221(b) of such 
Code is amended by redesignating paragraph (4) as paragraph (5) and by 
inserting after paragraph (3) the following new paragraph:
``(4) Applicable insurance company.--For purposes of 
subsection (a)(9), the term `applicable insurance company' 
means, with respect to any taxable year--
``(A) any insurance company other than an insurance 
company--
``(i) with respect to which an election is 
in effect under section 831(b)(2)(A)(iii) or 
835(a) for such taxable year,
``(ii) which is a foreign corporation 
described in section 842, or
``(iii) which is an organization to which 
section 833 applies for such taxable year, or
``(B) a face-amount certificate company registered 
under the Investment Company Act of 1940.''.
(c) Effective Date.--The amendments made by this section shall 
apply to notes, bonds, debentures, or other evidence of indebtedness 
acquired by an applicable insurance company (as defined in section 
1221(b)(4)) of such Code after December 31, 2025.

SEC. 3. CAPITAL LOSS CARRYOVERS INCURRED BY APPLICABLE INSURANCE 
COMPANIES ALLOWED FOR 10 YEARS.

(a) In General.--Section 1212(a)(1)(C) of the Internal Revenue Code 
of 1986 is amended to read as follows:
``(C) a capital loss carryover to each of the 10 
taxable years succeeding the loss year, but only to the 
extent such loss--
``(i) is attributable to a foreign 
expropriation loss, or
``(ii) was incurred by an applicable 
insurance company (as defined in section 
1221(b)(4)).''.
(b) Effective Date.--The amendment made by this section shall apply 
to net capital losses arising in taxable years beginning after December 
31, 2025.
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