US SB439

Excludes from federal gross income any capital gains from the sale of real property interests (full ownership, remainder interests, or perpetual use restrictions) to qualified organizations under the Department of Defense's Readiness and Environmental Protection Integration (REPI) program

REPI program (10 U.S.C. § 2684a) allows DoD to acquire land or development rights near military installations to prevent encroachment and protect training capabilities

Pass-through entities (partnerships, S corporations) cannot claim the exclusion if they acquired the property within 3 years of the REPI sale, unless the entity is substantially owned by an individual and family members

Mineral interests may be retained without disqualifying the property, provided surface mining access is not permitted

Applies to taxable years beginning after enactment; introduced February 6, 2025 by Senators Budd (R-NC) and Kaine (D-VA) with bipartisan support