PRIDE Act of 2025
The PRIDE Act of 2025 aims to promote parity for legally married same-sex couples in the federal tax code. Its two main pillars are: (1) extending the statute of limitations for certain amended tax returns for legally married same-sex couples who were treated as married under Revenue Ruling 2013-17, and (2) broad modernization of the Internal Revenue Code's language to be gender-neutral and to treat legally married same-sex couples the same as other married couples in all relevant provisions. In addition to the SOL relief, the bill rewrites numerous code sections to replace gender-specific terms (husband/wife, him/her, his spouse) with neutral terms (married couple, the taxpayer’s spouse, the individual's spouse, etc.), and it updates several definitions and treatment provisions so that a married couple is treated as a single unit where appropriate.
Key Points
- 1Extension of limitations period for amendments for certain legally married couples: For taxpayers who were first treated as married under Revenue Ruling 2013-17 and filed a non-joint return for a year ending before Sept. 16, 2013, the bill allows that return to be treated as a separate return, and delays the deadline for a later joint return or amended filing. The extended period applies through the date of enactment for the tax year that includes that date, and credits/refunds claims on joint returns filed under this extension are not subject to the normal 6511(b)(2) limits.
- 2Amendments limited to change in marital status: The extensions above apply only to amendments or credit/refund claims that relate to a change in marital status, ensuring retroactive relief is targeted to those who changed their marital status in a way recognized by the code.
- 3Broad gender-neutral rewrite of the IRC (Section 3): The bill systematically replaces gendered terms with neutral language (e.g., “husband and wife” becomes “married couple”; “himself” becomes “self”). It also redefines certain provisions so a married couple is treated as 1 partner in relevant contexts and updates multiple sections to reflect that all provisions apply to legally married same-sex couples in the same manner as opposite-sex couples.
- 4Comprehensive cross-references and conformity: The bill makes conforming amendments to the table of sections and to subchapters to reflect the new terminology, notably replacing references to “joint returns by husband and wife” with “joint returns by a married couple.”
- 5Section 4: Rules relating to gender of spouses, etc.: This section further strips gendered language across many parts of the Code, replacing “his spouse” with “the taxpayer’s spouse” or similar phrasing, and making parallel changes to ensure consistent gender-neutral terminology and interpretations.