I 
119TH CONGRESS 
1ST SESSION H. R. 1822 
To amend the Internal Revenue Code of 1986 to exclude from gross income 
interest received on certain loans secured by rural or agricultural real 
property. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 4, 2025 
Mr. FEENSTRA (for himself, Mr. DAVIS of North Carolina, and Mr. MORAN) 
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 
from gross income interest received on certain loans se-
cured by rural or agricultural real property. 
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 ‘‘Access to Credit for 
our Rural Economy Act of 2025’’ or the ‘‘ACRE Act of 
2025’’. 
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SEC. 2. EXCLUSION OF INTEREST ON LOANS SECURED BY 
RURAL OR AGRICULTURAL REAL PROPERTY. 
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 is amended 
by inserting after section 139I the following new section: 
‘‘SEC. 139J. INTEREST ON LOANS SECURED BY RURAL OR 
AGRICULTURAL REAL PROPERTY. 
‘‘(a) IN GENERAL.—Gross income shall not include 
interest received by a qualified lender on any qualified real 
estate loan. 
‘‘(b) QUALIFIED LENDER.—For purposes of this sec-
tion, the term ‘qualified lender’ means— 
‘‘(1) any bank or savings association the depos-
its of which are insured under the Federal Deposit 
Insurance Act (12 U.S.C. 1811 et seq.), 
‘‘(2) any State- or Federally-regulated insur-
ance company, 
‘‘(3) any entity wholly owned, directly or indi-
rectly, by a company that is treated as a bank hold-
ing company for purposes of section 8 of the Inter-
national Banking Act of 1978 (12 U.S.C. 3106) if— 
‘‘(A) such entity is organized, incor-
porated, or established under the laws of the 
United States or any State of the United 
States, and 
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‘‘(B) the principal place of business of 
such entity is in the United States (including 
any territory of the United States), 
‘‘(4) any entity wholly owned, directly or indi-
rectly, by a company that is considered an insurance 
holding company under the laws of any State if such 
entity satisfies the requirements described in sub-
paragraphs (A) and (B) of paragraph (3), and 
‘‘(5) with respect to interest received on a quali-
fied real estate loan secured by real estate described 
in subsection (c)(3)(A), any federally chartered in-
strumentality of the United States established under 
section 8.1(a) of the Farm Credit Act of 1971 (12 
U.S.C. 2279aa–1(a)). 
‘‘(c) QUALIFIED REAL ESTATE LOAN.—For purposes 
of this section— 
‘‘(1) IN GENERAL.—The term ‘qualified real es-
tate loan’ means any loan— 
‘‘(A) secured by— 
‘‘(i) rural or agricultural real estate or 
forestland, or 
‘‘(ii) a leasehold mortgage (with a sta-
tus as a lien) on rural or agricultural real 
estate, 
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‘‘(B) which is made to a person other than 
a foreign adversary entity, 
‘‘(C) in the case of any loan with respect 
to single family residence described in para-
graph (3)(B)— 
‘‘(i) the proceeds of which are used to 
purchase or improve such residence, and 
‘‘(ii) the principal of which (when 
added to the principal of all other such 
loans with respect to such residence) does 
not (as of the time the interest income on 
such loan is accrued) exceed $750,000, and 
‘‘(D) made after the date of the enactment 
of this section. 
For purposes of the preceding sentence, the deter-
mination of whether property securing such loan is 
rural or agricultural real estate shall be made as of 
the time the interest income on such loan is accrued. 
‘‘(2) REFINANCINGS.—For purposes of sub-
paragraphs (A) and (C) of paragraph (1), a loan 
shall not be treated as made after the date of the 
enactment of this section to the extent that the pro-
ceeds of such loan are used to refinance a loan 
which was made on or before the date of the enact-
ment of this Act (or, in the case of any series of 
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refinancings, the original loan was made on or be-
fore such date). 
‘‘(3) RURAL
OR
AGRICULTURAL
REAL
ES-
TATE.—The term ‘rural or agricultural real estate’ 
means— 
‘‘(A) any real property which is substan-
tially used for the production of one or more 
agricultural products, 
‘‘(B) any single family residence— 
‘‘(i) which is the principal residence 
(within the meaning of section 121) of its 
occupant, and 
‘‘(ii) which is located in a rural area 
within the meaning of section 1.11(b)(3) of 
the Agricultural Credit Act of 1987 (12 
U.S.C. 2019(b)(3)), 
‘‘(C) any real property which is substan-
tially used in the trade or business of fishing or 
seafood processing, and 
‘‘(D) any aquaculture facility. 
‘‘(4) 
AQUACULTURE
FACILITY.—The 
term 
‘aquaculture facility’ means any land, structure, or 
other appurtenance that is used for aquaculture (in-
cluding any hatchery, rearing pond, raceway, pen, or 
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incubator) that is located in any State or any terri-
tory of the United States. 
‘‘(5) FOREIGN ADVERSARY ENTITY.— 
‘‘(A) IN GENERAL.—The term ‘foreign ad-
versary entity’ means— 
‘‘(i) a foreign adversary, 
‘‘(ii) a foreign person subject to the 
jurisdiction of, or organized under the laws 
of, a foreign adversary, and 
‘‘(iii) a foreign person owned, di-
rected, or controlled by an entity described 
in clause (i) or (ii). 
‘‘(B) FOREIGN
ADVERSARY.—The term 
‘foreign adversary’ means— 
‘‘(i) the People’s Republic of China, 
including all Special Administrative Re-
gions, 
‘‘(ii) the Republic of Cuba, 
‘‘(iii) the Islamic Republic of Iran, 
‘‘(iv) the Democratic People’s Repub-
lic of Korea, 
‘‘(v) the Russian Federation, and 
‘‘(vi) the Bolivarian Republic of Ven-
ezuela during any period of time in which 
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Nichola´s Maduro is President of the Re-
public. 
‘‘(d) COORDINATION WITH SECTION 265.—Qualified 
real estate loans shall be treated as obligations described 
in section 265(a)(2) the interest on which is wholly exempt 
from the taxes imposed by this subtitle.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for part III of subchapter B of chapter 1 of the Internal 
Revenue Code of 1986 is amended by inserting after the 
item relating to section 139I the following new item: 
‘‘Sec. 139J. Interest on loans secured by rural or agricultural real property.’’. 
(c) REPORT TO CONGRESS.—Not later than 5 years 
after the date of the enactment of this Act, the Secretary 
of the Treasury (or the Secretary’s delegate) shall submit 
a written report to the Committee on Ways and Means 
of House of Representatives and the Committee on Fi-
nance of the Senate analyzing the impact of section 139J 
of the Internal Revenue Code of 1986 (as added by sub-
section (a)) on qualified real estate loans (as defined in 
such section), including whether such section has resulted 
in a reduction in the rate of interest on such loans. 
(d) 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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