To amend the Internal Revenue Code of 1986 to exclude certain discharges of indebtedness secured by real property from income.
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
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
Identified Costs
- Federal government (U.S. Treasury)
- U.S. taxpayers generally
Sponsors
Legislative Progress
IntroducedMs. 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.
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
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "IRS"
- → Internal Revenue Service (enforcement authority)
- "the_taxpayer"
- → Commercial or retail property owner claiming the exclusion
Key Definitions
Terms defined in this bill
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
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