HR4115-119

Introduced

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

119th Congress Introduced Jun 24, 2025

Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.

Summary

What This Bill Does

The bill creates a tax exclusion allowing commercial and retail property owners to exclude from taxable income the discharge of qualified debt secured by commercial real property. It relies on tax exclusion and definition changes. The main policy areas are Finance and Taxation.

Who Benefits and How

Shopping mall owners and retail property landlords with distressed debt could see lower costs, Real Estate Investment Trusts (REITs) focused on retail properties could see lower costs, and Commercial real estate developers and retail center operators could see lower costs.

Who Bears the Burden and How

Federal government (U.S. Treasury) could lose revenue opportunities and U.S. taxpayers generally could face higher costs.

Key Provisions

  • Creates a tax exclusion allowing commercial and retail property owners to exclude from taxable income the discharge of qualified debt secured by commercial real property.

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

The bill creates a tax exclusion allowing commercial and retail property owners to exclude from taxable income the discharge of qualified debt secured by commercial real property.

Key Policy Areas

Finance, Taxation

Primary Purpose

The bill creates a tax exclusion allowing commercial and retail property owners to exclude from taxable income the discharge of qualified debt secured by commercial real property.

Policy Domains

Finance Taxation

Section 1 - Short Title

Identified Gains
  • Shopping mall owners and retail property landlords with distressed debt
  • Real Estate Investment Trusts (REITs) focused on retail properties
  • Commercial real estate developers and retail center operators
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: ih
Commercial real estate developers and retail center operators:
Real Estate Investment Trusts (REITs) focused on retail properties:
Shopping mall owners and retail property landlords with distressed debt:
Identified Costs
  • Federal government (U.S. Treasury)
  • U.S. taxpayers generally
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: ih
U.S. taxpayers generally:
Federal government (U.S. Treasury):

Legislative Progress

Introduced
Introduced Committee Passed
Jun 24, 2025

Ms. Tenney (for herself, Mr. Tonko, Mr. Lawler, and Mr. …

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Real Estate
3 mentions across 1 clause
+3 positive

Commercial real estate developers and retail center operators, Real Estate Investment Trusts (REITs) focused on retail properties, Shopping mall owners and retail property landlords with distressed debt

Government
1 mention across 1 clause
-1 negative

Federal government (U.S. Treasury)

General Public
1 mention across 1 clause
-1 negative

U.S. taxpayers generally

1/2
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Finance Taxation
Domains
Taxation Commercial Real Estate Retail Industry
Actor Mappings
"IRS"
→ Internal Revenue Service (enforcement authority)
"the_taxpayer"
→ Commercial or retail property owner claiming the exclusion

Key Definitions

Terms defined in this bill

2 terms
"qualified commercial or retail indebtedness" §2(b)(j)(1)

Indebtedness that was (A) incurred or assumed before March 1, 2023, (B) discharged between December 31, 2023 and January 1, 2028, and (C) secured by specified real property at all times between incurrence and discharge

"specified real property" §2(b)(j)(2)

Real property that is (A) used in a trade or business, (B) not residential rental property (not in IRC 168(b)(3)(B)), and (C) not exempt facility property (not in IRC 144(c)(6)(B))

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology