119-hr2912

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2912 Introduced in House

    (IH) ]

<DOC>

119th CONGRESS
 1st Session
 H. R. 2912

 To amend the Internal Revenue Code of 1986 to establish a wealth tax, 
 and for other purposes.

_______________________________________________________________________

 IN THE HOUSE OF REPRESENTATIVES

 April 14, 2025

Ms. Lee of Pennsylvania (for herself, Ms. Tlaib, Mr. Nadler, Mr. Frost, 
 Ms. Norton, Ms. Dean of Pennsylvania, Mrs. Ramirez, Mr. Huffman, Mrs. 
Foushee, and Mrs. Watson Coleman) introduced the following bill; which 
 was referred to the Committee on Ways and Means

_______________________________________________________________________

 A BILL

 To amend the Internal Revenue Code of 1986 to establish a wealth tax, 
 and for other purposes.

 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 ``Oligarch Act of 2025''.

SEC. 2. IMPOSITION OF WEALTH TAX.

    (a) In General.--The Internal Revenue Code of 1986 is amended by 
inserting after subtitle B the following new subtitle:

 ``Subtitle B-1--Wealth Tax

 ``Chapter 18--Determination of Wealth Tax

 ``CHAPTER 18--DETERMINATION OF WEALTH TAX

``

Sec. 2901. Imposition of tax.
``

Sec. 2902. Net value of taxable assets.
``

Sec. 2903. Special rules.
``

Sec. 2904. Information reporting.
``

Sec. 2905. Enforcement.

``

SEC. 2901. IMPOSITION OF TAX.

 ``

    (a) In General.--In the case of any applicable taxpayer, a tax is 
hereby imposed on the net value of all taxable assets of the taxpayer 
on the last day of any calendar year.
 ``

    (b) Computation of Tax.--
 ``

    (1) Individuals.--In the case of an individual, the tax 
 imposed by this section shall be equal to the sum of--
 ``
        (A) 2 percent of so much of the net value of all 
 taxable assets of the taxpayer as exceed the threshold 
 amount but do not exceed the product of 10 multiplied 
 by threshold amount,
 ``
        (B) 4 percent of so much of the net value of all 
 taxable assets of the taxpayer as exceed the product of 
 10 multiplied by the threshold amount but do not exceed 
 the product of 100 multiplied by the threshold amount,
 ``
            (C) 6 percent of so much of the net value of all 
 taxable assets of the taxpayer as exceed the product of 
 100 multiplied by the threshold amount but do not 
 exceed the product of 1,000 multiplied by the threshold 
 amount, plus
 ``
            (D) 8 percent of so much of the net value of all 
 taxable assets of the taxpayer as exceed the product of 
 1,000 multiplied by the threshold amount.
 ``

    (2) Trusts.--In the case of a trust, the tax imposed by 
 this section shall be equal to 8 percent of so much of the net 
 value of all taxable assets of the taxpayer as exceed the 
 threshold amount.
 ``
            (c) Applicable Taxpayer.--
 ``

    (1) In general.--The term `applicable taxpayer' means any 
 individual or any trust (other than a trust described in 
 

section 401

    (a) and exempt from tax under 

section 501

    (a) ).
 ``

    (2) Treatment of married individuals.--For purposes of 
 this section, individuals who are married (as defined in 
 

section 7703) shall be treated as one applicable taxpayer.
 ``
            (d) Threshold Amount.--For purposes of this section, the term 
`threshold amount' means the amount that is the product of 1,000 
multiplied by the greater of--
 ``

    (1) $50,000, or
 ``

    (2) the applicable median household wealth.
 ``

    (e) Applicable Median Household Wealth.--The Secretary shall 
annually determine the median household wealth with respect to the 
United States for purposes of this section.
 ``

    (f) Application to Trusts.--
 ``

    (1) Attribution of assets in trust.--In determining the 
 assets of a taxpayer for purposes of subsection

    (a) :
 ``
        (A) Grantor trust.--In the case of a grantor 
 trust, the grantor shall be treated as holding all the 
 assets of the trust.
 ``
        (B) Beneficiary trust.--In the case of a 
 beneficiary trust, each beneficiary of the trust shall 
 be treated as holding a fraction of the assets of the 
 trust in proportion to such beneficiary's interest in 
 such trust.
 ``

    (2) Property of trusts.--Any asset treated as held by a 
 grantor or beneficiary under paragraph

    (1) shall not be treated 
 as held by the trust for purposes of this section.
 ``

    (3) Trusts relating to common beneficiaries.--Trusts 
 benefitting substantially the same beneficiaries shall be 
 treated as a single applicable taxpayer for purposes of this 
 section.
 ``

    (4) === Definitions. ===
-For purposes of this section:
 ``
        (A) Grantor trust.--The term `grantor trust' 
 means a trust in which a taxpayer is treated as owning 
 an asset of the trust under subpart E of part I of 
 subchapter J of chapter 1.
 ``
        (B) Beneficiary trust.--The term `beneficiary 
 trust' means any trust that is not a grantor trust.
 ``

    (g) Regulations.--The Secretary shall issue such regulations or 
other guidance as may be necessary or appropriate to carry out the 
purposes of this section, including--
 ``

    (1) regulations establishing a process by which a 
 beneficiary may demonstrate the portion of such beneficiary's 
 interest in a trust, and
 ``

    (2) regulations for determining the appropriate 
 attribution of assets in a trust for purposes of subsection

    (e)

    (1) in the case of a trust with multiple grantors.

``

SEC. 2902. NET VALUE OF TAXABLE ASSETS.

 ``

    (a) In General.--For purposes of this subtitle, the term `net 
value of all taxable assets' means, as of any date, the excess of--
 ``

    (1) the value of all property of the taxpayer (other than 
 property excluded under subsection

    (b) ), real or personal, 
 tangible or intangible, wherever situated, over
 ``

    (2) any debts (including any debts secured by property 
 excluded under subsection

    (b) ) owed by the taxpayer.
 ``

    (b) Exclusion for Certain Assets Under $50,000.--Property of the 
taxpayer shall not be taken into account under subsection

    (a) if such 
property--
 ``

    (1) has a value of $50,000 or less (determined without 
 regard to any debt owed by the taxpayer with respect to such 
 property),
 ``

    (2) is tangible personal property, and
 ``

    (3) is not property--
 ``
        (A) which is used in a trade or business of the 
 taxpayer,
 ``
        (B) in connection with which a deduction is 
 allowable under 

section 212, or
 ``
            (C) which is a collectible as defined in 

section 408
            (m) , a boat, an aircraft, a mobile home, a trailer, 
 a vehicle, or an antique or other asset that maintains 
 or increases its value over time (within the meaning of 
 

section 5.02

    (2) of Revenue Procedure 2018-08).
 ``
            (c) Rules for Determining Property of the Taxpayer.--For purposes 
of this subtitle:
 ``

    (1) Property included in estate.--Any property that would 
 be included in the estate of the taxpayer if the taxpayer died 
 shall be treated as property of the taxpayer.
 ``

    (2) Inclusion of certain gifts.--Any property transferred 
 by the taxpayer after the date of the enactment of this 
 chapter, to an individual who is a member of the family of the 
 taxpayer (as determined under 

section 267
            (c) (4) ) and has not 
 attained the age of 18 shall be treated as property of the 
 taxpayer for any calendar year before the year in which such 
 individual attains the age of 18.
 ``
            (d) Establishment of Valuation Rules.--Not later than 12 months 
after the date of the enactment of this section, the Secretary shall 
establish rules and methods for determining the value of any asset for 
purposes of this subtitle, including rules for the valuation of assets 
that are not publicly traded or that do not have a readily 
ascertainable value. Such rules and methods--
 ``

    (1) may utilize retrospective and prospective formulaic 
 valuation methods not currently in use by the Secretary,
 ``

    (2) may require the use of formulaic valuation approaches 
 for designated assets, including formulaic approaches based on 
 proxies for determining presumptive valuations, formulaic 
 approaches based on prospective adjustments from purchase 
 prices or other prior events, or formulaic approaches based on 
 retrospectively adding deferral charges based on eventual sale 
 prices or other specified later events indicative of valuation, 
 and
 ``

    (3) may address the use of valuation discounts.

``

SEC. 2903. SPECIAL RULES.

 ``

    (a) Deceased Individuals.--
 ``

    (1) In general.--In the case of any individual who dies 
 during a calendar year and who is not married on the date of 
 such individual's death--
 ``
        (A) section 2901 shall be applied by substituting 
 `the date of the applicable taxpayer's death' for `the 
 last day of any calendar year', and
 ``
        (B) the amount of the tax imposed under such 
 section shall be reduced by an amount which bears the 
 same ratio to such amount (determined without regard to 
 this subsection) as--
 ``
            (i) the number of days in the calendar 
 year after the date of the individual's death, 
 bears to
 ``
            (ii) 365.
 ``

    (2) Coordination with estate tax.--For purposes of 
 

section 2053, the tax imposed by this section for the year of 
 the decedent's death shall be considered to have been imposed 
 before such death.
 ``

    (b) Application to Non-Residents.--In the case of any nonresident 
alien individual, this subtitle shall apply only to the property of 
such individual which is situated in the United States (determined 
under rules similar to the rules under subchapter B of chapter 11).
 ``
            (c) Application to Covered Expatriates.--In the case of an 
individual who is a covered expatriate (as defined in 

section 877A), 

section 2901

    (a) shall be applied as if the calendar year ended on the 
day before the expatriation.

``

SEC. 2904. INFORMATION REPORTING.

 ``

    (a) In General.--Not later than 12 months after the date of the 
enactment of this section, the Secretary shall by regulation require 
the reporting of any information concerning the net value of assets 
appropriate to enforce the tax imposed by this chapter.
 ``

    (b) Method of Reporting.--The Secretary shall, where appropriate, 
require the reporting made under subsection

    (a) to be made as a part of 
existing income reporting requirements (including requirements under 
chapter 4 (relating to taxes to enforce reporting on certain foreign 
accounts)).
 ``
            (c) Responsibility for Reporting.--The Secretary may impose 
reporting obligations by reference to the ownership, control, 
management, claim to income from, or other relationship to assets and 
liabilities for purposes of administering the tax imposed by this 
section and may impose such obligations on financial institutions, 
business entities, or other persons, including requiring business 
entities to provide estimates of the value of the entity itself.

``

SEC. 2905. ENFORCEMENT.

 ``The Secretary shall annually audit not less than 30 percent of 
taxpayers required to pay the tax imposed under this chapter.''.

    (b) No Deduction From Income Taxes.--

Section 275 of such Code is 
amended by inserting after paragraph

    (6) the following new paragraph:
 ``

    (7) Taxes imposed by chapter 18.''.
            (c) Extension of Time for Payment of Tax.--

    (1) In general.--

Section 6161

    (a) of such Code is amended by 
 adding at the end the following new paragraph:
 ``

    (3) Wealth tax.--
 ``
        (A) In general.--In the case of an applicable 
 taxpayer described in subparagraph
        (B) , the Secretary 
 may extend the time for payment of the tax imposed 
 under chapter 18 for a reasonable period not to exceed 
 5 years from the date fixed for the payment thereof.
 ``
        (B) Taxpayers described.--An applicable taxpayer 
 is described in this subparagraph if such the Secretary 
 determines--
 ``
            (i) the applicable taxpayer has severe 
 liquidity constraints, or
 ``
            (ii) immediate payment would cause undue 
 hardship on an ongoing enterprise.
 ``
            (C) Applicable taxpayer.--For purposes of this 
 paragraph, the term `applicable taxpayer' has the 
 meaning given such term in 

section 2901.''.

    (2) Rules.--Not later than 12 months after the date of the 
 enactment of this Act, the Secretary of the Treasury (or the 
 Secretary's delegate) shall establish rules for the application 
 of the amendments made by paragraph

    (1) .
            (d) Application of Accuracy Related Penalties.--

    (1) In general.--

Section 6662

    (b) of such Code is amended by 
 inserting after paragraph

    (10) the following new paragraph:
 ``

    (11) Any substantial wealth tax valuation 
 understatement.''.

    (2) Substantial wealth tax understatement.--

Section 6662 of 
 such Code is amended by adding at the end the following new 
 subsection:
 ``
            (m) Application to Substantial Wealth Tax Valuation 
Understatement.--
 ``

    (1) Substantial wealth tax valuation understatement 
 defined.--
 ``
        (A) In general.--For purposes of this section, 
 there is a substantial wealth tax valuation 
 understatement if the value of any property claimed on 
 any return of tax is 65 percent or less of the amount 
 determined to be the correct amount of such valuation.
 ``
        (B) Limitation.--No penalty shall be imposed by 
 reason of subsection

    (b)

    (11) unless the portion of the 
 underpayment attributable to substantial wealth tax 
 valuation understatements for the calendar year exceeds 
 $5,000.
 ``

    (2) Increased penalty.--
 ``
        (A) In general.--In the case of any portion of an 
 underpayment which is attributable to one or more 
 substantial wealth tax valuation understatement, 
 subsection

    (a) shall be applied--
 ``
            (i) in the case of a substantial wealth 
 tax valuation understatement which is a gross 
 wealth tax valuation misstatement, by 
 substituting `50 percent' for `20 percent', and
 ``
            (ii) in any other case, by substituting 
 `30 percent' for `20 percent'.
 ``
        (B) Gross wealth tax valuation misstatement.--For 
 purposes of subparagraph
        (A) , the term `gross wealth 
 tax valuation misstatement' means a substantial wealth 
 tax valuation understatement, as determined under 
 paragraph

    (1) by substituting `40 percent' for `65 
 percent'.''.

    (e) Exemption of Tax-Exempt Entities.--

Section 501

    (a) of such Code 
is amended by inserting ``and subtitle B-1'' after ``this subtitle''.

    (f) Clerical Amendment.--The table of subtitles of such Code is 
amended by inserting after the item relating to subtitle B the 
following new item:

 ``Subtitle B-1--Wealth Tax''.

    (g) Effective Date.--The amendments made by this section shall 
apply to calendar years beginning after the date of the enactment of 
this Act.
 <all>