“any income and gain from the sale or other disposition (including pursuant to the deemed sale or other deemed disposition or a transaction subject to section 367(d)) of--”
The section adds a new subclause (VII) to section 250(b)(3)(A)(i) of the Internal Revenue Code of 1986 covering income and gain, except as the Secretary provides, from the sale or other disposition of intangible property as defined in section 367(d)(4) and of any other property subject to depreciation, amortization or depletion by the seller. It also inserts a carve-out reference for that subclause into section 250(b)(5)(E).
What the document actually says
“any income and gain from the sale or other disposition (including pursuant to the deemed sale or other deemed disposition or a transaction subject to section 367(d)) of--”
That sentence, in plain words
Income and gain from a sale is named. That covers a deemed sale as well as a real one. The two kinds of property follow.
What this is about
One is intangible property such as a patent. The other is property written down over time. Both are taken out of the income figure.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70322, 139 Stat. 204 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“Gains on intangible and depreciable property come out of the income figure,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70322, Sec. 70322. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70322-dispositions/ (retrieved August 26, 2026).
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