Overview

Title

To amend the Internal Revenue Code of 1986 to exclude from gross income interest received on certain loans secured by rural or agricultural real property.

ELI5 AI

H. R. 1822 is a plan that lets banks and other money-related companies avoid paying taxes on the money they earn from loans for farms and rural homes, hoping this will make it easier for people in the countryside to get loans.

Summary AI

H. R. 1822, also known as the "Access to Credit for our Rural Economy Act of 2025" or the "ACRE Act of 2025," proposes changes to the Internal Revenue Code of 1986. This bill seeks to allow banks, insurance companies, and certain government-related entities to exclude from their taxable income any interest earned on loans that are secured by rural or agricultural real estate. Specifically, this exclusion applies to loans used for agricultural purposes, fishing, seafood processing, and qualifying single-family residences in rural areas. The bill also requires a report to Congress after five years to assess the impact of this tax exclusion on loan interest rates.

Published

2025-03-04
Congress: 119
Session: 1
Chamber: HOUSE
Status: Introduced in House
Date: 2025-03-04
Package ID: BILLS-119hr1822ih

Bill Statistics

Size

Sections:
3
Words:
1,485
Pages:
7
Sentences:
23

Language

Nouns: 423
Verbs: 98
Adjectives: 97
Adverbs: 12
Numbers: 43
Entities: 86

Complexity

Average Token Length:
3.89
Average Sentence Length:
64.57
Token Entropy:
4.91
Readability (ARI):
32.52

AnalysisAI

General Summary of the Bill

The Access to Credit for our Rural Economy Act of 2025, or the ACRE Act of 2025, aims to amend the Internal Revenue Code of 1986. The primary focus of this bill is to exclude from gross income any interest received by qualified lenders on certain loans secured by rural or agricultural real property. This legislative proposal seeks to encourage lending in rural and agricultural areas by making such interest income tax-exempt, thereby theoretically incentivizing financial institutions to extend more credit in these sectors.

Summary of Significant Issues

Several significant issues arise from the provisions laid out in this bill:

  1. Favoritism towards Larger Financial Institutions: The definition of "qualified lender" in the bill appears to favor large banks, savings associations, insurance companies, and entities owned by them. This might inadvertently diminish the competitive edge of smaller financial institutions or individual lenders.

  2. Static Definition of Foreign Adversaries: The bill outlines specific countries as "foreign adversaries," potentially resulting in static and outdated geographic and political discrimination. The current global political dynamics may change, necessitating constant updates to the legislation to reflect these changes accurately.

  3. Potential Tax Revenue Loss: By excluding certain interest from gross income, the government may face substantial tax revenue losses. This raises concerns regarding whether the resulting economic activities in rural or agricultural sectors will compensate for the reduced revenue.

  4. Ambiguity in Definitions: Terms such as "rural or agricultural real estate," and references to external Acts, are not precisely defined. This lack of clarity could lead to inconsistencies across regions in determining loan eligibility, hindering fair implementation.

  5. Compliance and Understanding Challenges: The bill's complexity, with references to various external statutes, may pose challenges for non-experts trying to comply with the new law, possibly leading to misapplications.

  6. Regional Disparities in Real Estate Values: The specific monetary limits set for qualified loans, such as the $750,000 cap for single-family residences, might not account for the variation in real estate values across different regions, potentially causing inequities in loan qualification.

Impact on the Public Broadly

For the general public, especially those residing in rural or agricultural areas, this bill could potentially increase access to financing by making loans more attractive to lenders. Lower interest rates could be an indirect result if lenders decide to pass on the savings from tax exemptions to borrowers. However, the overall effectiveness of this incentive to stimulate the desired economic activity remains uncertain. If mishandled, the government might deal with a fiscal deficit without corresponding economic benefits in rural sectors.

Impact on Specific Stakeholders

Positive Impacts:

  • Lenders: Financial institutions qualifying under the defined criteria could see increased business opportunities with the ability to make more competitive loan offers.

  • Farmers and Rural Homeowners: Could benefit from increased availability of credit, potentially allowing for improvements and investments in their properties.

Negative Impacts:

  • Smaller Lending Entities: Might find themselves at a disadvantage, struggling to compete against more prominent institutions benefiting from the bill's preferential definitions.

  • Minority or Foreign-Owned Businesses: The exclusion of loans to entities connected to "foreign adversary" countries might adversely affect businesses with foreign ties or minority ownership, fostering potential stigma or discrimination based on national origin.

In summary, while the ACRE Act seeks to promote economic growth within the rural and agricultural sectors, it presents both opportunities and challenges. Thorough consideration and potentially further amendments might be necessary to ensure balanced benefits across all intended stakeholders without undesired consequences.

Financial Assessment

The Access to Credit for our Rural Economy Act of 2025 or ACRE Act of 2025 introduces significant financial implications within the tax framework by excluding certain interest income from taxable gross income. The primary financial reference in the bill pertains to loans secured by rural or agricultural real property, specifically allowing the exclusion of interest income from these loans for taxes purposes. This provision is intended to support economic activities in rural areas by reducing tax burdens on lenders, which could incentivize more lending in these sectors.

Exclusion of Interest from Gross Income

The bill allows financial institutions like banks, insurance companies, and certain government-related entities to exclude from their gross income any interest earned on loans secured by rural or agricultural real estate. The definition of a qualified real estate loan includes loans used for agricultural purposes, fishing, seafood processing, and single-family residences in rural areas. Notably, for a single-family residence to qualify, the loan principal cannot exceed $750,000.

Potential Revenue Implications

This exclusion could lead to a substantial decrease in tax revenue collected by the government. By allowing certain lenders to exclude interest from taxable income, the government loses potential revenue that would have otherwise been collected from these entities. Such a financial loss might be justified if it leads to increased economic growth and development in rural areas; however, the act does not provide explicit evidence or projections on whether this tax incentive will produce the desired economic outcomes.

Efficiency and Fairness Concerns

The bill sets a monetary limit of $750,000 for loan principals that can benefit from this exclusion when securing single-family residences in rural areas. This uniform cap does not consider regional differences in real estate prices, potentially leading to inequities. For instance, in areas where real estate is more costly, the cap might be insufficient to cover even modest homes, reducing the accessibility and fairness of this financial benefit.

Moreover, the bill's exclusionary provisions for loans linked to foreign adversary entities raise ethical and fairness issues since entities located in specific countries are categorically denied benefits based on political affiliations rather than financial criteria.

Impact Assessment Requirement

The bill mandates a report to Congress five years following its enactment to assess the impact of this tax exclusion on interest rates for qualified loans. This future evaluation is crucial, as it will provide insights into whether the tax exclusion leads to more favorable lending terms for borrowers, thereby indirectly addressing concerns over revenue loss by evaluating the broader economic benefits.

In conclusion, while the ACRE Act of 2025 aims to stimulate economic activity in rural regions through tax incentives, it introduces complexities related to tax revenue impacts, fairness, and equitable access based on regional variations in real estate values. The mandated report will be a pivotal document in determining the success and continued viability of these financial provisions.

Issues

  • The definition of 'qualified lender' in Section 2 might favor larger financial institutions such as banks and insurance companies over smaller lenders and individuals, potentially reducing competitive opportunities for smaller entities and affecting market dynamics.

  • The description of 'foreign adversary' countries in Section 2(c)(5)(B) is static and could lead to unintended discrimination against entities from specific countries even if geopolitical circumstances change, requiring frequent legislative updates.

  • The provision to exclude interest from gross income on loans secured by rural or agricultural real property may result in significant tax revenue loss without clear evidence that it will effectively stimulate desired economic activities, as highlighted in Sections 2 and 139J.

  • The term 'rural or agricultural real estate' is not precisely defined in Section 139J, which could lead to ambiguity and inconsistency in determining loan eligibility across different areas, impacting fairness and implementation.

  • The complexity and language of the bill, especially in referencing external documents like the Agricultural Credit Act of 1987, may make it difficult for non-experts to fully understand the implications, leading to potential misapplication or compliance challenges, as noted in Sections 2 and 139J.

  • The use of specific monetary limits (e.g., $750,000 for single-family residences) in Section 2 may not consider regional variations in real estate values, potentially resulting in inequities and challenges in loan qualifications.

  • The legislation's exclusion of loans made to foreign adversary entities, as defined in Section 2(c)(5), could lead to ethical concerns over fairness and discrimination based on national origin.

Sections

Sections are presented as they are annotated in the original legislative text. Any missing headers, numbers, or non-consecutive order is due to the original text.

1. Short title Read Opens in new tab

Summary AI

The first section of the Act provides its official name, which is the “Access to Credit for our Rural Economy Act of 2025” or simply the “ACRE Act of 2025.”

2. Exclusion of interest on loans secured by rural or agricultural real property Read Opens in new tab

Summary AI

The section introduces a new part to the Internal Revenue Code that allows qualified lenders to receive tax-free interest on loans secured by rural or agricultural property. It specifies what qualifies as a "qualified lender," describes what types of loans and properties are qualified, and emphasizes that the loans must not be given to foreign adversaries.

Money References

  • “(c) Qualified real estate loan.—For purposes of this section— “(1) IN GENERAL.—The term ‘qualified real estate loan’ means any loan— “(A) secured by— “(i) rural or agricultural real estate or forestland, or “(ii) a leasehold mortgage (with a status as a lien) on rural or agricultural real estate, “(B) which is made to a person other than a foreign adversary entity, “(C) in the case of any loan with respect to single family residence described in paragraph (3)(B)— “(i) the proceeds of which are used to purchase or improve such residence, and “(ii) the principal of which (when added to the principal of all other such loans with respect to such residence) does not (as of the time the interest income on such loan is accrued) exceed $750,000, and “(D) made after the date of the enactment of this section.

139J. Interest on loans secured by rural or agricultural real property Read Opens in new tab

Summary AI

In this section, interest income from loans on rural or agricultural properties is exempt from gross income for qualified lenders, which include certain banks, insurance companies, and entities related to them. The loans must be used for approved purposes, like purchasing or improving a single-family home, and should not exceed certain limits, while also excluding foreign adversary entities.

Money References

  • if— (A) such entity is organized, incorporated, or established under the laws of the United States or any State of the United States, and (B) the principal place of business of such entity is in the United States (including any territory of the United States), (4) any entity wholly owned, directly or indirectly, by a company that is considered an insurance holding company under the laws of any State if such entity satisfies the requirements described in subparagraphs (A) and (B) of paragraph (3), and (5) with respect to interest received on a qualified real estate loan secured by real estate described in subsection (c)(3)(A), any federally chartered instrumentality of the United States established under section 8.1(a) of the Farm Credit Act of 1971 (12 U.S.C. 2279aa–1(a)). (c) Qualified real estate loan.—For purposes of this section— (1) IN GENERAL.—The term “qualified real estate loan” means any loan— (A) secured by— (i) rural or agricultural real estate or forestland, or (ii) a leasehold mortgage (with a status as a lien) on rural or agricultural real estate, (B) which is made to a person other than a foreign adversary entity, (C) in the case of any loan with respect to single family residence described in paragraph (3)(B)— (i) the proceeds of which are used to purchase or improve such residence, and (ii) the principal of which (when added to the principal of all other such loans with respect to such residence) does not (as of the time the interest income on such loan is accrued) exceed $750,000, and (D) made after the date of the enactment of this section.