A Democratic bill with 22 Democratic cosponsors · See all 23 cosponsors
Last activity — Read twice and referred to the Committee on Finance.
In committee
Introduced and handed to a committee in the chamber it started in.
The committee holds it, and most bills are never heard from again. A hearing or a committee vote would be news; silence is the usual outcome, and it kills the bill without anyone voting against it.
Its path through Congress
- Introduced
- In Committee
What this bill would do
The Billionaires Income Tax Act aims to stop billionaires from avoiding taxes indefinitely through strategies like "buy, borrow, die" by requiring high-income and high-net-worth individuals to pay annual taxes using mark-to-market taxation. The bill closes loopholes related to appreciated assets, deferred compensation, and specific life insurance contracts while modifying rules for trusts and pass-through entities. It also establishes new reporting and penalty rules for private placement life insurance and annuity contracts. Additionally, it removes certain tax exclusions for qualified small business stock and limits basis adjustments for Qualified Opportunity Funds for applicable taxpayers and entities.
Yes· 3 of 8
- Scored +10
Does this raise taxes on the highest earners?
The bill imposes annual mark-to-market taxation and closes major loopholes specifically targeting ultra-wealthy individuals.
- Scored +6
Does this reduce what the federal government owes?
New annual tax revenues from billionaires will likely contribute significantly to reducing federal deficits.
- Scored +5
Does this make the government pay for what it commits to?
Ensures continuous annual tax collection from high-net-worth individuals, promoting long-term fiscal stability.
The opposite· 3 of 5
- Scored -10
Would high-income households be better off under this?
Substantially increases tax liabilities and eliminates long-term tax deferral strategies for individuals with over $100M in income or $1B in assets.
- Scored -10
Would people with substantial wealth be better off under this?
Directly targets high-net-worth individuals by eliminating traditional tax avoidance planning strategies.
- Scored -10
Would the very wealthiest people be better off under this?
Specifically designed to require billionaires to pay annual taxes on unrealized capital gains and eliminate tax deferrals.
Who it would affect, and how
Potential Positive Impacts for People
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Fairer Tax System: The bill requires high-income and high-net-worth taxpayers to pay taxes on an annual basis, similar to how working people pay taxes on wages (Section 2).
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Closing Wealth Loopholes: It eliminates the ability of the ultra-wealthy to hold appreciating assets and borrow against them tax-free to fund their lifestyles (Section 2).
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Preventing Intergenerational Tax Avoidance: The bill closes the loophole that allows wealthy taxpayers to pass untaxed appreciated assets to heirs who can then sell them tax-free (Section 2).
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Taxing Expatriates: It implements special rules for covered expatriates who are applicable taxpayers, ensuring they remain taxable for a 10-year period following their expatriation date (Section 202).
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Information Transparency: Under section 6050CC(b), people receiving amounts from private placement life insurance and annuity contracts must be provided with a written statement by January 31 of the following year, ensuring they have necessary documentation.
Potential Negative Impacts for People
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Increased Tax Burden for High-Net-Worth Individuals: "Applicable taxpayers" (those meeting specific income or asset tests) will face higher annual tax liabilities due to the elimination of tax deferrals (Section 490).
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Additional Penalties on Compensation: Applicable taxpayers will face a "deferral recapture amount" (interest) on deferred compensation and a 10% tax on severance pay (Section 409B).
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Loss of Life Insurance Tax Benefits: The bill repeals the exclusion for death benefits for applicable private placement life or annuity contracts, meaning these payments may now be taxable (Section 222(c)).
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Stricter Rules for Entities: Applicable entities may lose the ability to use like-kind exchanges (Section 211) or certain tax-free transfers in exchange for stock (Section 212).
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Increased Penalties: Section 6724(d) is amended to include penalties for failing to follow the new return and statement requirements related to private placement life insurance and annuity contracts.
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Loss of Tax Exclusion: Section 231 removes the tax exclusion for gains from the sale or exchange of qualified small business stock for "applicable taxpayers" for stock acquired on or after September 17, 2025.
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Restrictions on Opportunity Fund Elections: Section 232(a) prevents "applicable taxpayers" and "applicable entities" from making certain elections regarding sales or exchanges in Qualified Opportunity Funds under specific conditions.
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Reduced Basis Adjustments: Section 232(b) changes the basis calculation for Qualified Opportunity Fund investments held for 10 years for "applicable taxpayers" and "applicable entities," potentially limiting the fair market value used to determine the basis.
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Tap or hover a score for the reason it gave.
- Demographic And Interest Groups
- Would households on low incomes be better off under this? — Increased federal revenues could potentially fund social programs benefiting lower-income populations. Would middle-income households be better off under this? — Shifts tax burdens away from wage-earning middle-class taxpayers toward ultra-wealthy asset holders. Would billionaires be better off under this? — The core purpose of the bill is to eliminate tax loopholes and collect annual income taxes from billionaires. Would high-income households be better off under this? — Substantially increases tax liabilities and eliminates long-term tax deferral strategies for individuals with over $100M in income or $1B in assets. Would people with substantial wealth be better off under this? — Directly targets high-net-worth individuals by eliminating traditional tax avoidance planning strategies. Would the very wealthiest people be better off under this? — Specifically designed to require billionaires to pay annual taxes on unrealized capital gains and eliminate tax deferrals. Would business owners be better off under this? — Imposes heavy compliance, reporting, and mark-to-market valuation requirements on significant owners of pass-through entities.
- Economy And Finance
- Does this raise taxes on the highest earners? — The bill imposes annual mark-to-market taxation and closes major loopholes specifically targeting ultra-wealthy individuals. Does this reduce what the federal government owes? — New annual tax revenues from billionaires will likely contribute significantly to reducing federal deficits. Does this make the government pay for what it commits to? — Ensures continuous annual tax collection from high-net-worth individuals, promoting long-term fiscal stability.
- Governance And Ideology
- Does this make what the government does easier for the public to see? — Requires detailed asset reporting and tracking for billionaires and complex pass-through entities. Does this give the federal government more power? — Expands federal tax oversight and regulatory authority over ultra-high-net-worth individual assets.
- Social Issues And Justice
- Does this narrow racial gaps in how people are treated? — Addressing extreme wealth concentration indirectly supports broader economic equity initiatives.
- 9/14/2026
- 1 Cosponsor added.
- 8/6/2026
- 1 Cosponsor added.
- 9/30/2025
- 1 Cosponsor added.
- 9/17/2025
- Read twice and referred to the Committee on Finance.
- 20 Cosponsors added.
- Introduced in Senate
2 bills Congress.gov lists as related to this one — companions in the other chamber, earlier versions, and bills this one absorbed or was folded into.
Angela AlsobrooksDemocrat · Maryland
Tammy BaldwinDemocrat · Wisconsin
Richard BlumenthalDemocrat · Connecticut
Christopher CoonsDemocrat · Delaware
Tammy DuckworthDemocrat · Illinois
John FettermanDemocrat · Pennsylvania
Mazie HironoDemocrat · Hawaii
Martin HeinrichDemocrat · New Mexico
Ben LujánDemocrat · New Mexico
Edward MarkeyDemocrat · Massachusetts
Patty MurrayDemocrat · Washington
Christopher MurphyDemocrat · Connecticut
Jeff MerkleyDemocrat · Oregon
Alex PadillaDemocrat · California
John ReedDemocrat · Rhode Island
Bernie SandersIndependent · Vermont
Adam SchiffDemocrat · California
Brian SchatzDemocrat · Hawaii
Tina SmithDemocrat · Minnesota
Chris Van HollenDemocrat · Maryland
Peter WelchDemocrat · Vermont
Sheldon WhitehouseDemocrat · Rhode Island
Elizabeth WarrenDemocrat · Massachusetts