Secure Family Futures Act of 2025

[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.

_______________________________________________________________________

                    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

_______________________________________________________________________

                                 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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