I 
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 Representa-
tives 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’’. 
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SEC. 2. DEBT NOT TREATED AS CAPITAL ASSET FOR APPLI-
CABLE 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 para-
graph: 
‘‘(9) any note, bond, debenture, or other evi-
dence of indebtedness held by an applicable insur-
ance 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 tax-
able 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 
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‘‘(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 APPLI-
CABLE INSURANCE COMPANIES ALLOWED 
FOR 10 YEARS. 
(a) IN GENERAL.—Section 1212(a)(1)(C) of the In-
ternal Revenue Code of 1986 is amended to read as fol-
lows: 
‘‘(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 expro-
priation loss, or 
‘‘(ii) was incurred by an applicable in-
surance company (as defined in section 
1221(b)(4)).’’. 
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(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to net capital losses arising in tax-
able years beginning after December 31, 2025. 
Æ 
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