H.R. 2534

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

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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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