H.R. 2547 — Secure Family Futures Act of 2025

This section excludes from the definition of capital assets any note, bond, debenture, or other evidence of indebtedness held by an applicable insurance company. An applicable insurance company is any insurance company other than (1) one electing under IRC §831(b) (micro-captive insurers), IRC §835(a) (premium method), or qualifying as a foreign corporation under IRC §842 or a Blue Cross/Blue Shield organization under IRC §833, or (2) a face-amount certificate company under the Investment Company Act of 1940. (Thus, for such companies, gains or losses on sales of these debt instruments will receive ordinary income tax treatment rather than capital gains treatment.) The exclusion applies to debt acquired after December 31, 2025.

This section allows capital losses incurred by applicable insurance companies (as defined in IRC §1221(b)(4))—in addition to foreign expropriation losses—to be carried forward to each of the 10 taxable years succeeding the loss year (generally 5 years under IRC §1212(a)(1)(B)). The amendment applies to net capital losses arising in taxable years beginning after December 31, 2025.