This part takes gains on the sale of intangible and depreciable property out of one income figure. It also narrows which costs are charged against that income. Interest and research costs are left out.
“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.
“expenses and deductions (including taxes), other than interest expense and research or experimental expenditures, properly allocable to such gross income.”
The section rewrites section 250(b)(3)(A)(ii) of the Internal Revenue Code of 1986 so that only expenses and deductions, including taxes, properly allocable to the gross income are charged against it, and not interest expense or research or experimental expenditures.
What the document actually says
“expenses and deductions (including taxes), other than interest expense and research or experimental expenditures, properly allocable to such gross income.”
That sentence, in plain words
Costs are charged against the income only if they belong to it. Interest and research costs are left out.
What this is about
Taxes are among the costs that may be charged. The rule narrows what may be counted. That raises 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.
The document says “shall apply”Who acts: Secretary of the TreasuryHow: statuteSec. 70322 in the PDF
What the document says
“The amendments made by this subsection shall apply to sales or other dispositions (including pursuant to deemed sales or other deemed dispositions or a transaction subject to section 367(d) of the Internal Revenue Code of 1986) occurring after June 16, 2025.”
The section applies the change on sales and dispositions to those occurring after June 16, 2025, and applies the change on expense apportionment to taxable years beginning after December 31, 2025.
What the document actually says
“The amendments made by this subsection shall apply to sales or other dispositions (including pursuant to deemed sales or other deemed dispositions or a transaction subject to section 367(d) of the Internal Revenue Code of 1986) occurring after June 16, 2025.”
That sentence, in plain words
The first change reaches sales made after June 16, 2025. A deemed sale counts as a sale here.
What this is about
The second change works by tax year. It starts with years that begin after December 31, 2025. Both dates are fixed in the law.
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.
Each distinct thing the section does: add the new subclause taking sale and disposition income out of the figure, narrow the expenses charged against gross income, and fix the two effective dates.
The conforming amendment inserting a carve-out reference into section 250(b)(5)(E), and the mechanical edits that fix the punctuation of a list.
The section works by amending section 250(b) of the Internal Revenue Code of 1986 and points to section 367(d), neither of which is indexed here.
