119-hr2534

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2534 Introduced in House

    (IH) ]

<DOC>

119th CONGRESS
 1st Session
 H. R. 2534

 To ensure high-income earners pay a fair share of Federal taxes.

_______________________________________________________________________

 IN THE HOUSE OF REPRESENTATIVES

 April 1, 2025

 Mr. Boyle of Pennsylvania (for himself, Mr. Khanna, and Ms. Norton) 
 introduced the following bill; which was referred to the Committee on 
 Ways and Means

_______________________________________________________________________

 A BILL

 To ensure high-income earners pay a fair share of Federal taxes.

 Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

 This Act may be cited as the ``Paying a Fair Share Act of 2025''.

SEC. 2. FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS.

    (a) In General.--Subchapter A of chapter 1 of the Internal Revenue 
Code of 1986 is amended by adding at the end the following new part:

 ``PART VIII--FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS

``

Sec. 59B. Fair share tax.

``

SEC. 59B. FAIR SHARE TAX.

 ``

    (a) General Rule.--
 ``

    (1) Phase-in of tax.--In the case of any high-income 
 taxpayer, there is hereby imposed for a taxable year (in 
 addition to any other tax imposed by this subtitle) a tax equal 
 to the product of--
 ``
        (A) the amount determined under paragraph

    (2) , 
 and
 ``
        (B) a fraction (not to exceed 1)--
 ``
            (i) the numerator of which is the excess 
 of--
 ``
            (I) the taxpayer's adjusted gross 
 income, over
 ``
            (II) the dollar amount in effect 
 under subsection
            (c) (1) , and
 ``
            (ii) the denominator of which is the 
 dollar amount in effect under subsection
            (c) (1) .
 ``

    (2) Amount of tax.--The amount of tax determined under 
 this paragraph is an amount equal to the excess (if any) of--
 ``
        (A) the tentative fair share tax for the taxable 
 year, over
 ``
        (B) the excess of--
 ``
            (i) the sum of--
 ``
            (I) the regular tax liability (as 
 defined in 

section 26

    (b) ) for the 
 taxable year, determined without regard 
 to any tax liability determined under 
 this section,
 ``
            (II) the tax imposed by 

section 55 for the taxable year, plus
 ``
            (III) the payroll tax for the 
 taxable year, over
 ``
            (ii) the credits allowable under part IV 
 of subchapter A (other than sections 27

    (a) , 31, 
 and 34).
 ``

    (b) Tentative Fair Share Tax.--For purposes of this section--
 ``

    (1) In general.--The tentative fair share tax for the 
 taxable year is 30 percent of the excess of--
 ``
        (A) the adjusted gross income of the taxpayer, 
 over
 ``
        (B) the modified charitable contribution 
 deduction for the taxable year.
 ``

    (2) Modified charitable contribution deduction.--For 
 purposes of paragraph

    (1) --
 ``
        (A) In general.--The modified charitable 
 contribution deduction for any taxable year is an 
 amount equal to the amount which bears the same ratio 
 to the deduction allowable under 

section 170 (

section 642
            (c) in the case of a trust or estate) for such 
 taxable year as--
 ``
            (i) the amount of itemized deductions 
 allowable under the regular tax (as defined in 
 

section 55) for such taxable year, determined 
 after the application of 

section 68, bears to
 ``
            (ii) such amount, determined before the 
 application of 

section 68.
 ``
        (B) Taxpayer must itemize.--In the case of any 
 individual who does not elect to itemize deductions for 
 the taxable year, the modified charitable contribution 
 deduction shall be zero.
 ``
            (c) High-Income Taxpayer.--For purposes of this section--
 ``

    (1) In general.--The term `high-income taxpayer' means, 
 with respect to any taxable year, any taxpayer (other than a 
 corporation) with an adjusted gross income for such taxable 
 year in excess of $1,000,000 (50 percent of such amount in the 
 case of a married individual who files a separate return).
 ``

    (2) Inflation adjustment.--
 ``
        (A) In general.--In the case of a taxable year 
 beginning after 2025, the $1,000,000 amount under 
 paragraph

    (1) shall be increased by an amount equal 
 to--
 ``
            (i) such dollar amount, multiplied by
 ``
            (ii) the cost-of-living adjustment 
 determined under 

section 1

    (f)

    (3) for the 
 calendar year in which the taxable year begins, 
 determined by substituting `calendar year 2024' 
 for `calendar year 2016' in subparagraph
        (A)
            (ii) thereof.
 ``
        (B) Rounding.--If any amount as adjusted under 
 subparagraph
        (A) is not a multiple of $10,000, such 
 amount shall be rounded to the next lowest multiple of 
 $10,000.
 ``
            (d) Payroll Tax.--For purposes of this section, the payroll tax 
for any taxable year is an amount equal to the excess of--
 ``

    (1) the taxes imposed on the taxpayer under sections 
 1401, 1411, 3101, 3201, and 3211

    (a) (to the extent such tax is 
 attributable to the rate of tax in effect under 

section 3101) 
 with respect to such taxable year or wages or compensation 
 received during such taxable year, over
 ``

    (2) the deduction allowable under 

section 164

    (f) for such 
 taxable year.
 ``

    (e) Special Rule for Estates and Trusts.--For purposes of this 
section, in the case of an estate or trust, adjusted gross income shall 
be computed in the manner described in 

section 67

    (e) .
 ``

    (f) Not Treated as Tax Imposed by This Chapter for Certain 

=== Purposes ===
-The tax imposed under this section shall not be treated as 
tax imposed by this chapter for purposes of determining the amount of 
any credit under this chapter (other than the credit allowed under 

section 27

    (a) ) or for purposes of 

section 55.''.

    (b) Clerical Amendment.--The table of parts for subchapter A of 
chapter 1 of the Internal Revenue Code of 1986 is amended by adding at 
the end the following new item:

 ``Part VIII--Fair Share Tax on High-Income Taxpayers''.
            (c) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2024.

SEC. 3. SENSE OF THE HOUSE REGARDING TAX REFORM.

 It is the sense of the House of Representatives that--

    (1) Congress should enact tax reform that repeals unfair 
 and unnecessary tax loopholes and expenditures, simplifies the 
 system for millions of taxpayers and businesses, and makes sure 
 that the wealthiest taxpayers pay a fair share; and

    (2) this Act is an interim step that can be done quickly 
 and serve as a floor on taxes for the highest-income taxpayers, 
 cut the deficit by billions of dollars a year, and help 
 encourage more fundamental reform of the tax system.
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