H.R. 7138

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 7138 Introduced in House (IH)]

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119th CONGRESS
2d Session
H. R. 7138

To amend the Internal Revenue Code of 1986 to disallow the deduction of 
certain expenses relating to ownership of single-family homes by 
specified large investors, to impose an excise tax on the sale of such 
homes by such investors, and to prohibit Federal mortgage assistance 
relating to certain large investors.

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IN THE HOUSE OF REPRESENTATIVES

January 16, 2026

Mr. Khanna (for himself, Mrs. Watson Coleman, Mr. Deluzio, Mr. Garcia 
of Illinois, Mr. Jackson of Illinois, Ms. Simon, Mr. Takano, Mr. Frost, 
Ms. Tlaib, Ms. Tokuda, Ms. Lee of Pennsylvania, Ms. Kelly of Illinois, 
Mrs. Cherfilus-McCormick, and Mr. Thanedar) introduced the following 
bill; which was referred to the Committee on Ways and Means, and in 
addition to the Committee on Financial Services, for a period to be 
subsequently determined by the Speaker, in each case for consideration 
of such provisions as fall within the jurisdiction of the committee 
concerned

_______________________________________________________________________

A BILL

To amend the Internal Revenue Code of 1986 to disallow the deduction of 
certain expenses relating to ownership of single-family homes by 
specified large investors, to impose an excise tax on the sale of such 
homes by such investors, and to prohibit Federal mortgage assistance 
relating to certain large investors.

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 ``Stop Wall Street Landlords Act of 
2026''.

SEC. 2. DISALLOWANCE OF DEDUCTION OF CERTAIN EXPENSES RELATED TO 
SINGLE-FAMILY HOMES HELD BY SPECIFIED LARGE INVESTORS.

(a) In General.--Part IX of subchapter B of Chapter 1 of subtitle A 
of the Internal Revenue Code of 1986 is amended by adding at the end 
the following new section:

``SEC. 280I. CERTAIN EXPENSES RELATED TO SINGLE-FAMILY HOMES HELD BY 
SPECIFIED LARGE INVESTORS.

``(a) In General.--In the case of a specified large investor, no 
deduction shall be allowed under this chapter for the following 
expenses relating to the ownership of a single-family home:
``(1) Amounts paid or incurred for the interest on a 
mortgage relating to such single-family home or to insure such 
single-family home.
``(2) Depreciation of such single-family home.
``(b) Specified Large Investor.--For purposes of this section--
``(1) In general.--The term `specified large investor' 
means any person for any taxable year if the aggregate fair 
market value of all assets of such person (reduced by the 
aggregate debts of the taxpayer) exceeds $100,000,000 at any 
time during such taxable year.
``(2) Treatment of controlled groups.--For purposes of this 
subsection--
``(A) In general.--All persons which are part of a 
controlled group (within the meaning of section 1563(a) 
applied by substituting `more than 50 percent' for `at 
least 80 percent' each place it appears) shall be 
treated as 1 person.
``(B) Nonincorporated persons under common 
control.--Under regulations or other guidance provided 
by the Secretary, principles similar to the principles 
of subparagraph (A) shall apply to a group of persons 
under common control where 1 or more of such persons is 
not a corporation.
``(3) Government entities and certain tax-exempt 
entities.--Such term shall not include either of the following:
``(A) Any governmental entity.
``(B) Any organization which is described in 
section 501(c)(3) and exempt from tax under section 
501(a).
``(c) Single-Family Home.--
``(1) In general.--For purposes of this section, the term 
`single-family home' means any real property located in the 
United States if such property includes at least 1 dwelling 
unit and not more than 4 dwelling units.
``(2) Exception for federally-assisted buildings.--For 
purposes of this section--
``(A) In general.--Such term shall not include any 
federally-assisted building.
``(B) Federally-assisted building.--The term 
`federally-assisted building' means any building--
``(i) which is substantially assisted, 
financed, or operated under section 8 of the 
United States Housing Act of 1937, section 
221(d)(3), 221(d)(4), or 236 of the National 
Housing Act, section 515 of the Housing Act of 
1949, or any other housing program administered 
by the Department of Housing and Urban 
Development or by the Rural Housing Service of 
the Department of Agriculture,
``(ii) with respect to which a credit is 
allowed to the taxpayer under section 42, or
``(iii) for which financing is provided by 
a qualified bond (within the meaning of section 
141).
``(d) Exceptions.--
``(1) Principal residence.--In the case of a specified 
large investor who is an individual, subsection (a) shall not 
apply to any single-family home if such home is used as the 
principal residence of such investor.
``(2) Original construction or substantial 
rehabilitation.--Subsection (a) shall not apply with respect to 
a single-family home originally constructed or substantially 
rehabilitated (as defined in section 47(c)) by the taxpayer.''.
(b) Clerical Amendment.--The table of sections for part IX of 
subchapter B of chapter 1 of such Code is amended by inserting after 
the item relating to section 280H the following new item:

``Sec. 280I. Certain expenses related to single-family homes held by 
specified large investors.''.
(c) Effective Date.--The amendments made by this section shall 
apply to amounts paid or incurred and depreciation that occurs after 
the date that is 18 months after the date of the enactment of this Act.

SEC. 3. EXCISE TAX ON TRANSFERS OF SINGLE-FAMILY HOMES BY SPECIFIED 
LARGE INVESTORS.

(a) In General.--Chapter 36 of subtitle D of the Internal Revenue 
Code of 1986 is amended by inserting after subchapter D the following 
new subchapter:

``Subchapter E--Tax on Transfers of Single-Family Homes by Specified 
Large Investors

``Sec. 4491. Tax on transfers of single-family homes by specified large 
investors.

``SEC. 4491. TAX ON TRANSFERS OF SINGLE-FAMILY HOMES BY SPECIFIED LARGE 
INVESTORS.

``(a) In General.--There is hereby imposed a tax on the sale or 
transfer of a single-family home by a specified large investor in an 
amount equal to the sale price of the single-family home.
``(b) Specified Large Investor; Single-family Home.--For purposes 
of this section, the terms `specified large investor' and `single-
family home' shall have the respective meanings given such terms in 
section 280I.
``(c) Special Rules.--Rules similar to the rules of subsections 
(b)(2), (d)(1), and (d)(2) of section 280I shall apply for purposes of 
this section.''.
(b) Clerical Amendment.--The table of subchapters for chapter 36 of 
subtitle D of such Code is amended by adding after the item relating to 
subchapter D the following new item:

``subchapter e. tax on transfers of single-family homes by specified 
large investors.''.

(c) Effective Date.--The amendments made by this section shall 
apply to sales and transfers occurring after the date that is 18 months 
after the date of the enactment of this Act.

SEC. 4. LOW-INCOME HOUSING ASSISTANCE.

(a) Deposit of Funds.--Amounts collected in any penalty under 
section 3 shall be deposited in the Housing Trust Fund established 
under section 1338 of the Federal Housing Enterprises Financial Safety 
and Soundness Act of 1992 (12 U.S.C. 4568).
(b) Use of Funds.--To the extent provided for in advance in 
appropriations Acts, the amounts deposited in the Fund shall be used to 
increase and preserve the supply of rental housing affordable to 
extremely low- and very low-income families, including homeless 
families, in accordance with such section 1338.

SEC. 5. PROHIBITIONS ON FEDERAL MORTGAGE ASSISTANCE.

(a) Fannie Mae and Freddie Mac.--Subpart A of part 2 of subtitle A 
of title XIII of the Housing and Community Development Act of 1992 (12 
U.S.C. 4541 et seq.) is amended by adding at the end the following new 
section:

``SEC. 1329. PROHIBITION RELATING TO SPECIFIED LARGE INVESTORS.

``The Director shall, by regulation, prohibit the enterprises from 
newly purchasing any mortgage on a single-family housing or any portion 
thereof (or any interest in such a mortgage), and from newly lending on 
the security of or securitizing any such mortgage under which the 
mortgagee is a specified large investor (as such term is defined in of 
the Internal Revenue Code of 1986).''.
(b) Ginnie Mae.--Section 302(c) of the National Housing Act (12 
U.S.C. 1717(c)) is amended by adding at the end the following new 
paragraph:
``(6) The Association may not newly guarantee the payment 
of principal of or interest on any trust certificate or other 
security based or backed by a trust or pool that contains, or 
purchase or acquire, any mortgage under which the mortgagee is 
a specified large investor (as such term is defined in section 
280I(b) of the Internal Revenue Code of 1986).''.
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