Billionaires Income Tax Act
Sponsors
Legislative Progress
In CommitteeMr. Cohen (for himself, Mr. Beyer, Ms. Tlaib, Mr. García …
Primary Purpose
Impose annual mark-to-market taxation on billionaires and ultra-wealthy taxpayers (with over $100M income or $1B assets) to eliminate tax deferral strategies like 'buy, borrow, die' and require them to pay taxes on unrealized gains.
Policy Domains
Legislative Strategy
"Close the 'buy, borrow, die' loophole by requiring annual taxation of unrealized gains for ultra-wealthy taxpayers, while also closing related tax avoidance strategies through trusts, pass-through entities, deferred compensation, and other mechanisms."
Likely Beneficiaries
- Federal government (increased tax revenue from ultra-wealthy)
- General public (reduced federal deficit or increased funding for public services)
- Working taxpayers (reduced perception of unfairness in tax system)
Likely Burden Bearers
- Ultra-high-net-worth individuals (billionaires and those with $100M+ income)
- Private equity and hedge fund managers using pass-through entities
- Trust beneficiaries and estate planners for wealthy families
- Life insurance and annuity industry (private placement products)
- Tax advisors and wealth managers serving ultra-wealthy clients
- Companies issuing deferred compensation to executives
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
- "the_secretary"
- → Secretary of the Treasury
Key Definitions
Terms defined in this bill
The holding of a tradable covered asset as of the close of any taxable year for which taxpayer is an applicable taxpayer, OR any disregarded nonrecognition event.
Any asset other than: interests in applicable savings plans or defined benefit plans, cash or cash equivalents, or private placement life insurance or annuity contracts.
Any covered asset if interests are traded on an established securities market, readily tradable on a secondary market, available on an online platform matching buyers/sellers, or for which the Secretary determines there is a reasonable basis to determine fair market value annually.
Any covered asset which is not a tradable covered asset.
Exchanges under Section 351 or 1031, certain transfers involving C corporations, or other transactions the Secretary determines necessary to prevent avoidance of this part.
A pass-through entity (partnership, S corporation, or entity treated as partnership for tax purposes) in which an applicable taxpayer is a significant owner.
Any individual who meets the income test (adjusted gross income over $100M, or $50M if married filing separately) OR the asset test (aggregate value of covered assets over $1B, or $500M if married filing separately) for each of the 3 immediately preceding taxable years. Also includes applicable trusts and estates of individuals who were applicable taxpayers.
Compensation subject to Section 83 deferred beyond the normal vesting period, or other deferred compensation under Section 409A or similar arrangements.
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology