This bill proposes significant changes to the Internal Revenue Code concerning the tax treatment of certain insurance companies. It aims to modify how debt instruments are classified and how capital losses can be utilized by these entities. Specifically, the legislation amends Section 1221(a) to exclude notes, bonds, debentures, or other evidence of indebtedness held by an "applicable insurance company" from being treated as capital assets . An "applicable insurance company" is defined broadly, excluding certain types of insurers like small insurance companies or foreign corporations. Furthermore, the bill extends the capital loss carryover period for these applicable insurance companies from five years to ten years , aligning it with the treatment of foreign expropriation losses. These changes are set to take effect for debt acquired and net capital losses arising after December 31, 2025.