# 119-s-2095: PARTNERSHIPS Act 119-s-2095, PARTNERSHIPS Act, is a 119th Congress bill sponsored by Sen. Wyden, Ron [D-OR] (D-OR); status introduced; PRIA reads it as touching household money (as of 2025-12-21). - Canonical: https://policyrisk.com/legislation/119-s-2095 - As of: 2025-12-21 - Plain-text twin of the page above; the HTML and this file carry the same facts. ## Facts - Bill: 119-s-2095 - Congress: 119 - Title: PARTNERSHIPS Act - Status: introduced - Introduced: 2025-06-17 - Sponsor: Sen. Wyden, Ron [D-OR] (D-OR) - Cosponsors: 0 - Policy area: Taxation - Touches household money: yes - Last recorded action: 2025-12-21 ## Summary **This bill would overhaul how partnerships report and allocate taxable income and gains, and tighten rules to curb abusive or mismatched allocations.** It would force many partnerships to use a new “consistent percentage method” tied to partners’ net equity, add new reporting and deemed-transfer rules, and give Treasury broader regulatory authority. - Many partnerships and their partners would face new reporting and allocation rules. Covered partnerships must identify themselves and use a consistent percentage equal to each covered partner’s net equity for allocating income, loss, deductions, and credits. A partner with an “excess share” could be treated as transferring an interest and recognize immediate income with limits on deductible losses. - Liability shifts and transitional relief would affect partners who suddenly realize gain. Partnership liabilities would generally be allocated pro rata by profit share, effective for tax years after 2025, and taxpayers can elect to spread any gain caused by that change over six years. - Small business partnerships and distributions would face tighter basis rules. Section 754 elections would be limited to “qualified small business partnerships” under a gross receipts test, and distributions after enactment would trigger mandatory basis adjustments so remaining partners’ net liquidation amounts stay aligned. - High-income taxpayers, trusts, and estates would face a broader investment-income tax base. For taxpayers above the thresholds (about $400,000 single and $500,000 joint) the net investment income tax base would use a wider “specified net income” measure, with a phase-in cap on the extra tax of $100,000 (one-half for married filing separately), and similar substitution rules for trusts and estates. ## Provisions PRIA read - Earlier loss write-offs for worthless assets: benefit, high. If enacted, losses for worthless capital assets would be recognized when an identifiable event shows they are worthless, not just at year end. Abandonment would count as that identifiable event. A worthless partnership interest would be treated as a sale or exchange loss at the time of that event.… - Higher investment tax for high earners: cost, high. If enacted, the Net Investment Income Tax would apply to the greater of specified net income or net investment income for taxpayers over the bill's high-income thresholds. The thresholds are $400,000 for single filers, $500,000 for joint filers, and $250,000 for married filing separately. The added… - New basis rules for partnership distributions: cost, medium. If enacted, many partnerships could no longer make a section 754 basis adjustment unless they meet a small business gross receipts test. Partnerships would be required to adjust property basis so remaining partners keep the same net liquidation amounts after distributions. The bill would require th… - New partnership allocation and reporting rules: cost, medium. If enacted, covered partnerships would have new rules on how income, losses, and credits are divided and reported. Partnerships would need to tell the IRS they are a covered partnership and give new information about transfers of partnership interests. The bill would let Treasury recast or disregar… - Tax on transfers to investment funds: cost, medium. If enacted, transfers of marketable securities into certain investment companies or partnerships could trigger immediate taxable gain instead of nonrecognition. The rule covers transfers to registered investment companies, some exempt funds that offer interests to qualified purchasers, and transfer… - Reallocating partnership debt and payment option: mixed, medium. If enacted, partnership debts would generally be split by each partner's share of profits for tax basis and allocations. Guarantees would not get the same treatment and Treasury can write rules for similar arrangements. If that change causes taxable gain in the first year after 2025, affected taxpa… ## Related bills - 119-s-891: Bipartisan Health Care Act - 119-s-5071: Children's Safe Welcome Act of 2026 - 119-s-5022: Cannabis Administration and Opportunity Act - 119-s-2819: Head Start for America's Children Act - 119-s-4504: Full-Service Community School Expansion Act of 2026 - 119-s-3990: PrEP Access and Coverage Act of 2026 ## Sources - [119-s-2095 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/2095) ## Related - [119-s-891: Bipartisan Health Care Act](https://policyrisk.com/legislation/119-s-891) - [119-s-5071: Children's Safe Welcome Act of 2026](https://policyrisk.com/legislation/119-s-5071) - [119-s-5022: Cannabis Administration and Opportunity Act](https://policyrisk.com/legislation/119-s-5022) - [119-s-2819: Head Start for America's Children Act](https://policyrisk.com/legislation/119-s-2819) - [119-s-4504: Full-Service Community School Expansion Act of 2026](https://policyrisk.com/legislation/119-s-4504) - [119-s-3990: PrEP Access and Coverage Act of 2026](https://policyrisk.com/legislation/119-s-3990) - [All bills in Congress](https://policyrisk.com/legislation) Source: PRIA, https://policyrisk.com/legislation/119-s-2095 (as of 2025-12-21).