H.R. 2198 (119th)Bill Overview

To amend the Internal Revenue Code of 1986 to restore the taxable REIT subsidiary asset test.

Taxation|Taxation
Cosponsors
Support
Lean Republican
Introduced
Mar 18, 2025
Discussions
Bill Text
Current stageCommittee

Referred to the House Committee on Ways and Means.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief
Plain-English summaryWhat this bill actually does

This bill amends section 856(c)(4)(B)(ii) of the Internal Revenue Code by replacing "20 percent" with "25 percent." The change restores a previous asset-test threshold for taxable REIT subsidiaries. The amendment applies to taxable years beginning after December 31, 2025.

Why people may split

Liberals emphasize revenue loss and tax fairness concerns

Watch point

Relative to its intended legislative type, this bill is a narrowly tailored substantive policy change that precisely amends one provision of the Internal Revenue Code by changing a percent threshold and sets a clear effective date.

This bill amends section 856(c)(4)(B)(ii) of the Internal Revenue Code by replacing "20 percent" with "25 percent." The change restores a previous asset-test threshold for taxable REIT subsidiaries.

The amendment applies to taxable years beginning after December 31, 2025.

Passage40/100

Technically modest and noncontroversial but creates revenue effects; likelier if folded into a larger tax or budget package than as standalone.

CredibilityAligned

Relative to its intended legislative type, this bill is a narrowly tailored substantive policy change that precisely amends one provision of the Internal Revenue Code by changing a percent threshold and sets a clear effective date.

Contention55/100

Liberals emphasize revenue loss and tax fairness concerns

02 · What it does

Who stands to gain, and who may push back.

Likely benefits vs burdens50% / 50%
Likely helpedFederal agencies

These are examples from the analysis, not a ranked list of the most-affected groups.

Likely helped
  • Potential benefitAllows REITs greater flexibility to hold noncore assets inside taxable subsidiaries.
  • Potential benefitMay reduce the risk that operating activities jeopardize a REIT’s tax status.
  • Potential benefitCould encourage additional investment in REIT-controlled service and operating businesses.
Likely burdened
  • Federal agenciesCould reduce federal tax receipts if income shifts into structures that lower taxable income.
  • Potential burdenMay advantage larger REITs able to operate and fund taxable subsidiaries over smaller peers.
  • Potential burdenPotentially complicates compliance by increasing monitoring of asset allocation across REIT and TRS entities.
03 · Why people split

Why the argument around this bill splits.

Liberals emphasize revenue loss and tax fairness concerns
Progressive25%

Likely skeptical because the change benefits REIT structures and may reduce federal receipts.

Views it as a corporate tax rule tweak that favors real estate interests.

Would treat revenue and distributional impacts as primary concerns.

Likely resistant
Centrist50%

Mixed; sees this as a narrow, technical tax-code correction but wants evidence of net fiscal impact.

Supports restoring a prior threshold if accompanied by transparency and limited budget effect.

Looks for bipartisan, data-driven justification.

Split reaction
Conservative80%

Generally supportive; views the bill as pro-business, reducing burdens on REITs.

Sees restoring a 25 percent test as sensible deregulation that enhances market flexibility.

Opposed to offsets that would add taxes or constraints.

Leans supportive
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood40/100

Technically modest and noncontroversial but creates revenue effects; likelier if folded into a larger tax or budget package than as standalone.

Scope and complexity
24%
Scopenarrow
24%
Complexitylow
Why this could stall
  • Magnitude of revenue impact (no score included)
  • Level of organized industry support or opposition
05 · Recent votes

Recent votes on the bill.

No vote history yet

The bill has not accumulated any surfaced votes yet.

06 · Go deeper

Go deeper than the headline read.

Included on this page

Liberals emphasize revenue loss and tax fairness concerns

Technically modest and noncontroversial but creates revenue effects; likelier if folded into a larger tax or budget package than as standal…

Unlocked analysis

Relative to its intended legislative type, this bill is a narrowly tailored substantive policy change that precisely amends one provision of the Internal Revenue Code by changing a percent threshold and sets a clear eff…

Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.

Perspective breakdownsPassage barriersLegislative design reviewStakeholder impact map
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