S. 439 — Incentivizing Readiness and Environmental Protection Integration Sales Act of 2025

This section establishes an exclusion from gross income for gain from the sale of a qualified real property interest—such as a fee simple interest, remainder interest, or perpetual use restriction (including certain mineral interests without surface mining access)—to a qualified organization (as defined in IRC §170(h)(3)) for purposes of the Department of Defense's Readiness and Environmental Protection Integration (REPI) program under 10 U.S.C. §2684a. (As background, the REPI program authorizes the Secretary of Defense or a military department to enter agreements with states, localities, or conservation organizations to acquire or manage real property near military installations to limit incompatible development, preserve habitat, improve resilience, or protect clear zones.) The exclusion does not apply if a pass-through entity acquired the interest within three years of the sale, except for family partnerships or similar entities; the provision applies to taxable years beginning after enactment.