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This bill amends the Internal Revenue Code to exclude certain debt held by insurance companies from being treated as capital assets and extends the capital loss carryover period for those companies from 5 years to 10 years.
Sec. 2, Debt not treated as capital asset for applicable insurance companies: This section adds a new category to the list of assets that are not capital assets, specifically any note, bond, debenture, or other evidence of indebtedness held by an applicable insurance company. It defines an applicable insurance company as any insurance company except those that have elected certain tax treatments under sections 831(b)(2)(A)(iii) or 835(a), foreign corporations described in section 842, or organizations to which section 833 applies. It also includes face-amount certificate companies registered under the Investment Company Act of 1940. These changes apply to debt acquired after December 31, 2025.
Sec. 3, Capital loss carryovers incurred by applicable insurance companies allowed for 10 years: This section amends the capital loss carryover rules so that applicable insurance companies can carry over a net capital loss to each of the 10 taxable years after the loss year, instead of the current 5-year limit. This applies to net capital losses arising in taxable years beginning after December 31, 2025.
Summary of the bill text as introduced in Senate (Apr 8, 2025), generated by SecBot from the official bill text; the Library of Congress summary is not yet published.
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Official record from Congress.gov, the House Clerk and the Senate; lobbying from Lobbying Disclosure Act filings. Updated Oct 27, 2026.