S. 1335

119 S1335 IS: Secure Family Futures Act of 2025
 U.S. Senate
 2025-04-08
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 EN
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 II  119th CONGRESS  1st Session  S. 1335  IN THE SENATE OF THE UNITED STATES   April 8, 2025   Mr. Tillis  (for himself and  Mr. Warnock ) introduced the following bill; which was read twice and referred to the  Committee on Finance    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.
1.
Short title
This Act may be cited as the   Secure Family Futures Act of 2025  .
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.
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.