I 
119TH CONGRESS 
1ST SESSION H. R. 2089 
To amend the Internal Revenue Code of 1986 to allow individuals to defer 
recognition of reinvested capital gains distributions from regulated invest-
ment companies. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 11, 2025 
Ms. VAN DUYNE (for herself and Ms. SEWELL) 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 allow indi-
viduals to defer recognition of reinvested capital gains 
distributions from regulated investment companies. 
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 ‘‘Generating Retirement 
Ownership through Long-Term Holding’’. 
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SEC. 2. DEFERRAL OF REINVESTED CAPITAL GAIN DIVI-
DENDS OF REGULATED INVESTMENT COMPA-
NIES. 
(a) IN GENERAL.—Part III of subchapter O of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by inserting after section 1045 the following new section: 
‘‘SEC. 1046. REINVESTED CAPITAL GAIN DIVIDENDS OF 
REGULATED INVESTMENT COMPANIES. 
‘‘(a) NONRECOGNITION OF GAIN.—In the case of an 
individual, no gain shall be recognized on the receipt of 
a capital gain dividend distributed by a regulated invest-
ment company to which part I of subchapter M applies 
if such capital gain dividend is automatically reinvested 
in additional shares of the company pursuant to a dividend 
reinvestment plan. 
‘‘(b) DEFINITIONS AND SPECIAL RULES.—For pur-
poses of this section— 
‘‘(1) CAPITAL GAIN DIVIDEND.—The term ‘cap-
ital gain dividend’ has the meaning given to such 
term by section 852(b)(3)(C). 
‘‘(2) RECOGNITION
OF
DEFERRED
CAPITAL 
GAIN DIVIDENDS.— 
‘‘(A) IN GENERAL.—Gain treated as unrec-
ognized in accordance with subsection (a) shall 
be recognized in accordance with subparagraph 
(B)— 
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‘‘(i) upon a subsequent sale or re-
demption by such individual of stock in the 
distributing company, or 
‘‘(ii) upon the death of the individual. 
‘‘(B) GAIN RECOGNITION.— 
‘‘(i) IN GENERAL.—Upon a sale or re-
demption described in subparagraph (A), 
the taxpayer shall recognize that portion of 
total gain treated as unrecognized in ac-
cordance with subsection (a) (and not pre-
viously recognized pursuant to this sub-
paragraph) that is equivalent to the por-
tion of the taxpayer’s shares in the distrib-
uting company that are sold or redeemed. 
‘‘(ii) DEATH OF INDIVIDUAL.—Except 
as provided by regulations, any portion of 
such total gain not recognized under clause 
(i) prior to the taxpayer’s death shall be 
recognized upon the death of the taxpayer 
and included in the taxpayer’s gross in-
come for the taxable year ending on the 
date of the taxpayer’s death. 
‘‘(3) HOLDING PERIOD.—The taxpayer’s hold-
ing period in shares acquired through reinvestment 
of a capital gain dividend to which subsection (a) ap-
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plies shall be determined by treating the shareholder 
as having held such shares for one year and a day 
as of the date such shares are acquired. 
‘‘(c) SECTION NOT TO APPLY TO CERTAIN TAX-
PAYERS.—This section shall not apply to— 
‘‘(1) an individual with respect to whom a de-
duction under section 151 is allowable to another 
taxpayer for a taxable year beginning in the cal-
endar year in which such individual’s taxable year 
begins, or 
‘‘(2) an estate or trust. 
‘‘(d) REGULATIONS.—The Secretary shall prescribe 
such regulations as may be necessary to carry out the pur-
poses of this section.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 852(b)(3)(B) of such Code is 
amended by adding at the end the following new 
sentence: ‘‘For rules regarding nonrecognition of 
gain with respect to reinvested capital gain dividends 
received by individuals, see section 1046.’’. 
(2) The table of sections for part III of sub-
chapter O of chapter 1 of such Code is amended by 
inserting after the item relating to section 1045 the 
following new item: 
‘‘Sec. 1046. Reinvested capital gain dividends of regulated investment compa-
nies.’’. 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
Æ 
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