S3367-118

Introduced

To amend the Internal Revenue Code of 1986 to eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as buy, borrow, die, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes.

118th Congress Introduced Nov 30, 2023

Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.

Summary

What This Bill Does

This bill, To amend the Internal Revenue Code of 1986 to eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as buy, borrow, die, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes., changes federal law or congressional policy affecting financial institutions, investors, and borrowers. The main policy domain is Finance, Labor, Foreign Policy.

Who Benefits and How

financial institutions, investors, and borrowers may benefit from new authority, funding, eligibility, regulatory clarity, or reduced risk created by the bill.

Who Bears the Burden and How

federal implementing agencies, financial institutions, investors, and borrowers may take on implementation duties, reporting obligations, compliance costs, or oversight responsibilities.

Key Provisions

  • Section id69efd20c4a974d0c9d4a794a3d388f20: 1. Short title; amendment of 1986 Code; table of contents This Act may be cited as the Billionaires Income Tax Act. Except as otherwise expressly provided,...
  • Section id0d4364df9de2457b8b1f5b865dbae86e: 2. Purpose The purpose of this Act is to require billionaires to pay taxes annually by eliminating the ability of high income and high net worth taxpayers to...
  • Section id26394F31C2DE4A6EAC30A1D92676CA69: 101. Elimination of deferral of tax Subchapter E of chapter 1 is amended by adding at the end the following new part: IVElimination of deferral for applicable...
  • Section id11E2E244B034469FB08705B6BEB562E0: 490. Elimination of deferral of tax for applicable taxpayers In the case of an applicable taxpayer for any taxable year— if there is a taxable event with...
  • Section id642C19004BE749658C93A5FE9D52CAC8: 491. Treatment of tradable covered assets For purposes of this title, in the case of a taxable event with respect to any tradable covered asset of an...

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

This bill, To amend the Internal Revenue Code of 1986 to eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as buy, borrow, die, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes., changes federal law or congressional policy affecting financial institutions, investors, and borrowers.

Key Policy Areas

Finance, Labor, Foreign Policy

Primary Purpose

This bill, To amend the Internal Revenue Code of 1986 to eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as buy, borrow, die, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes., changes federal law or congressional policy affecting financial institutions, investors, and borrowers.

Policy Domains

Finance Labor Foreign Policy

Whole bill

Identified Gains
  • financial institutions, investors, and borrowers
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: is
financial institutions, investors, and borrowers: , ,
Identified Costs
  • federal implementing agencies
  • financial institutions, investors, and borrowers
Model: codex-gpt-5 | Version: bill_summary_v2 | Source: is
federal implementing agencies: , ,
financial institutions, investors, and borrowers: , ,

Legislative Progress

Introduced
Introduced Committee Passed
Nov 30, 2023

Mr. Wyden (for himself, Ms. Stabenow, Mr. Brown, Mr. Casey, …

Impact analysis is available but no clear stakeholder effects identified. View clause-level analysis →

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Finance Labor Foreign Policy
Actor Mappings
"secretary_of_treasury"
→ Secretary of the Treasury

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