I 
119TH CONGRESS 
1ST SESSION H. R. 4115 
To amend the Internal Revenue Code of 1986 to exclude certain discharges 
of indebtedness secured by real property from income. 
IN THE HOUSE OF REPRESENTATIVES 
JUNE 24, 2025 
Ms. TENNEY (for herself, Mr. TONKO, Mr. LAWLER, and Mr. RYAN) intro-
duced 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 
certain discharges of indebtedness secured by real prop-
erty from income. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Saving Our Mainstreet 
American Locations for Leisure and Shopping Act of 
2025’’, or the ‘‘Saving Our MALLS Act’’. 
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SEC. 2. EXCLUDING DISCHARGE OF COMMERCIAL OR RE-
TAIL INDEBTEDNESS FROM INCOME. 
(a) IN GENERAL.—Section 108(a)(1) of the Internal 
Revenue Code of 1986 is amended by striking ‘‘or’’ at the 
end of subparagraph (D), by striking the period at the 
end of subparagraph (E)(ii) and inserting ‘‘, or’’, and by 
adding at the end the following new subparagraph: 
‘‘(F) the indebtedness discharged is quali-
fied commercial or retail indebtedness.’’. 
(b) COMMERCIAL OR RETAIL INDEBTEDNESS DE-
FINED.—Section 108 of such code is amended by adding 
at the end the following new subsection: 
‘‘(j) COMMERCIAL OR RETAIL INDEBTEDNESS DE-
FINED.—For purposes of this section: 
‘‘(1) IN GENERAL.—The term qualified ‘com-
mercial or retail indebtedness’ means indebtedness 
which is— 
‘‘(A) incurred or assumed by the taxpayer 
before March 1, 2023, 
‘‘(B) discharged during the period begin-
ning on December 31, 2023, and ending on 
January 1, 2028, and 
‘‘(C) secured directly or indirectly by speci-
fied real property of the taxpayer at all times 
after such indebtedness was so incurred or as-
sumed and before such discharge. 
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‘‘(2) SPECIFIED
REAL
PROPERTY.—The term 
‘specified real property’ means real property which 
is— 
‘‘(A) used in a trade or business of the 
taxpayer, 
‘‘(B) 
not 
described 
in 
section 
168(b)(3)(B), and 
‘‘(C) 
not 
described 
in 
section 
144(c)(6)(B).’’. 
(c) COORDINATION OF EXCLUSIONS.— 
(1) Section 108(a)(2)(A) of such Code is 
amended by striking ‘‘and (E)’’ and inserting ‘‘(E), 
and (F)’’. 
(2) Section 108(a)(2)(B) is amended— 
(A) in the header, by striking ‘‘AND QUALI-
FIED REAL PROPERTY BUSINESS EXCLUSION’’ 
and inserting ‘‘, QUALIFIED
REAL
PROPERTY 
BUSINESS
EXCLUSION, AND
QUALIFIED
COM-
MERCIAL OR RETAIL INDEBTEDNESS’’, and 
(B) by striking ‘‘and (D)’’ and inserting 
‘‘(D), and (F)’’. 
(d) REDUCTION
OF
TAX
ATTRIBUTES.—Section 
108(b)(1) is amended by striking ‘‘or (C)’’ and inserting 
‘‘(C), or (F)’’. 
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(e) EFFECTIVE DATE.—The amendments made by 
this section apply to discharges of indebtedness occurring 
on or after December 31, 2023. 
Æ 
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