H.R. 8085

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 8085 Introduced in House (IH)]

<DOC>

119th CONGRESS
2d Session
H. R. 8085

To amend the Internal Revenue Code of 1986 to impose a tax on the net 
value of assets of a taxpayer, and for other purposes.

_______________________________________________________________________

IN THE HOUSE OF REPRESENTATIVES

March 25, 2026

Ms. Jayapal (for herself, Mr. Boyle of Pennsylvania, Ms. Ansari, Mr. 
Beyer, Ms. Chu, Mr. Davis of Illinois, Ms. Dean of Pennsylvania, Mr. 
Deluzio, Mr. DeSaulnier, Mrs. Foushee, Ms. Friedman, Mr. Frost, Mr. 
Garcia of Illinois, Mr. Garcia of California, Mr. Goldman of New York, 
Mrs. Grijalva, Mr. Ivey, Mr. Jackson of Illinois, Mr. Johnson of 
Georgia, Ms. Kelly of Illinois, Ms. Lee of Pennsylvania, Mr. McGovern, 
Mr. Nadler, Ms. Norton, Ms. Ocasio-Cortez, Ms. Omar, Mr. Pallone, Ms. 
Pressley, Mrs. Ramirez, Ms. Sanchez, Ms. Schakowsky, Ms. Simon, Mr. 
Smith of Washington, Ms. Stansbury, Mr. Takano, Mr. Thanedar, Ms. 
Tlaib, Ms. Tokuda, Ms. Velazquez, and Mrs. Watson Coleman) introduced 
the following bill; which was referred to the Committee on Ways and 
Means

_______________________________________________________________________

A BILL

To amend the Internal Revenue Code of 1986 to impose a tax on the net 
value of assets of a taxpayer, and for other purposes.

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 ``Ultra-Millionaire Tax Act of 2026''.

SEC. 2. IMPOSITION OF WEALTH TAX.

(a) In General.--The Internal Revenue Code of 1986 is amended by 
inserting after subtitle B the following new subtitle:

``Subtitle B-1--Wealth Tax

``Chapter 18--Determination of Wealth Tax

``CHAPTER 18--DETERMINATION OF WEALTH TAX

``Sec. 2901. Imposition of tax.
``Sec. 2902. Net value of taxable assets.
``Sec. 2903. Special rules.
``Sec. 2904. Information reporting.
``Sec. 2905. Enforcement.

``SEC. 2901. IMPOSITION OF TAX.

``(a) In General.--In the case of an individual, a tax is hereby 
imposed on the net value of all taxable assets of the taxpayer on the 
last day of any calendar year.
``(b) Computation of Tax.--
``(1) In general.--The tax imposed by this section shall be 
equal to the sum of--
``(A) 0 percent of so much of the net value of all 
taxable assets of the taxpayer as does not exceed the 
zero bracket threshold,
``(B) 2 percent of so much of the net value of all 
taxable assets of the taxpayer in excess of the zero 
bracket threshold but not in excess of the top bracket 
threshold, plus
``(C) the applicable percentage of so much of the 
net value of all such taxable assets of the taxpayer in 
excess of the top bracket threshold.
``(2) Zero bracket threshold; top bracket threshold.--For 
purposes of this section--
``(A) Zero bracket threshold.--The zero bracket 
threshold is $50,000,000.
``(B) Top bracket threshold.--The top bracket 
threshold is $1,000,000,000.
``(c) Applicable Percentage.--
``(1) In general.--For purposes of this section, the 
applicable percentage is--
``(A) except as provided in subparagraph (B), 3 
percent, and
``(B) in the case of any calendar year in which 
there is in effect legislation which meets the 
requirements of paragraph (2), 6 percent.
``(2) Legislation described.--Legislation meets the 
requirements of this paragraph if such legislation--
``(A) establishes a health insurance program that 
provides to all residents of the United States 
comprehensive protection against the costs of health 
care and health-related services, and
``(B) prohibits private entities from providing 
duplicate benefits.
``(d) Treatment of Married Individuals.--For purposes of this 
section, individuals who are married (as defined in section 7703) shall 
be treated as one taxpayer.
``(e) Treatment of Nongrantor Multibeneficiary Trusts.--
``(1) In general.--Any trust or portion of a trust which is 
a nongrantor multibeneficiary trust shall be treated as an 
individual to whom this chapter applies.
``(2) Computation of tax.--
``(A) In general.--In applying this chapter to a 
nongrantor multibeneficiary trust--
``(i) the zero bracket threshold shall be 
equal to the sum of--
``(I) $0, plus
``(II) the lowest unused 0 percent 
bracket amount assigned to the trust by 
all beneficiaries of the trust, and
``(ii) the top bracket threshold shall be 
equal to the sum of--
``(I) $0, plus
``(II) the lowest unused 2 percent 
bracket amount assigned to the trust by 
all beneficiaries of the trust.
``(B) Unused 0 percent bracket amount.--For 
purposes of this paragraph, the term `unused 0 percent 
bracket amount' means, with respect to any beneficiary 
for any calendar year, the lesser of--
``(i) the excess (if any) of--
``(I) the zero bracket threshold, 
over
``(II) the sum of--
``(aa) the net value of all 
taxable assets of the 
beneficiary for the calendar 
year, plus
``(bb) any unused 0 percent 
bracket amount assigned by the 
beneficiary to other nongrantor 
multibeneficiary trusts, or
``(ii) the portion of the net value of all 
taxable assets of the trust which such 
beneficiary is eligible to receive.
``(C) Unused 2 percent bracket amount.--For 
purposes of this paragraph, the term `unused 2 percent 
bracket amount' means, with respect to any beneficiary 
for any calendar year, the lesser of--
``(i) the excess (if any) of--
``(I) the top bracket threshold 
reduced by the zero bracket threshold, 
over
``(II) the sum of--
``(aa) the net value of all 
taxable assets of the 
beneficiary for the calendar 
year in excess of the zero 
bracket threshold, plus
``(bb) any unused 2 percent 
bracket amount assigned by the 
beneficiary to other nongrantor 
multibeneficiary trusts, or
``(ii) the portion of the net value of all 
taxable assets of the trust which such 
beneficiary is eligible to receive.
``(D) Assignment of amounts.--The assignment of any 
amount of unused 0 percent bracket amount and unused 2 
percent bracket amount shall be made at such time and 
in such manner as specified by the Secretary in 
regulations. In any case in which no affirmative 
assignment is made by a beneficiary, the amount 
assigned shall be $0.
``(3) Nongrantor multibeneficiary trust.--For purposes of 
this chapter--
``(A) In general.--The term `nongrantor 
multibeneficiary trust' means any trust or portion of a 
trust--
``(i) with respect to which no person is 
treated as an owner under subpart E of 
subchapter J of chapter 1,
``(ii) no property of which is attributable 
to a gratuitous transfer of assets by a person 
who is subject to tax under this chapter for 
the calendar year, and
``(iii) which has more than one beneficiary 
(determined as of the last day of the calendar 
year).
``(B) Exception.--Such term shall not include--
``(i) any trust described in section 401(a) 
and exempt from tax under section 501(a),
``(ii) any trust all of the unexpired 
interests in which are devoted to one or more 
of the purposes described in section 
170(c)(2)(B),
``(iii) any charitable lead annuity trust 
(as defined in section 2642(e)(3)) or 
charitable lead unitrust, or
``(iv) any charitable annuity remainder 
trust (as defined in section 664(d)(1)) or any 
charitable remainder unitrust (as defined in 
section 664(d)(2)).
``(C) Beneficiary.--The term `beneficiary' shall 
not include any person whose interest in a trust is 
contingent on the death of another person with an 
interest in such trust.

``SEC. 2902. NET VALUE OF TAXABLE ASSETS.

``(a) In General.--For purposes of this subtitle, the term `net 
value of all taxable assets' means, as of any date, the value of all 
property of the taxpayer (other than property excluded under subsection 
(b)), real or personal, tangible or intangible, wherever situated, 
reduced by any debts (including any debts secured by property excluded 
under subsection (b)) owed by the taxpayer.
``(b) Exclusion for Certain Assets.--Property of the taxpayer shall 
not be taken into account under subsection (a) if such property--
``(1) has a value of $50,000 or less (determined without 
regard to any debt owed by the taxpayer with respect to such 
property),
``(2) is tangible personal property, and
``(3) is not property--
``(A) which is used in a trade or business of the 
taxpayer,
``(B) in connection with which a deduction is 
allowable under section 212, or
``(C) which is a collectible as defined in section 
408(m), a boat, an aircraft, a mobile home, a trailer, 
a vehicle, or an antique or other asset that maintains 
or increases its value over time (within the meaning of 
section 5.02(2) of Revenue Procedure 2018-08).
``(c) Rules for Determining Property of the Taxpayer.--For purposes 
of this subtitle--
``(1) Property included in estate.--Any property that would 
be included in the estate of the taxpayer if the taxpayer died 
shall be treated as property of the taxpayer.
``(2) Inclusion of certain gifts.--Any property transferred 
by the taxpayer after the date of the enactment of this 
chapter, to an individual who is a member of the family of the 
taxpayer (as determined under section 267(c)(4)) and has not 
attained the age of 18 shall be treated as property of the 
taxpayer for any calendar year before the year in which such 
individual attains the age of 18.
``(3) Attribution of property held by trusts.--
``(A) Grantor trusts.--If an individual is treated 
as the owner of any portion of a trust under subpart E 
of subchapter J of chapter 1, property attributable to 
such trust or portion of the trust shall be treated as 
property of the individual and not as property of the 
trust.
``(B) Nongrantor trusts.--
``(i) In general.--In the case of a trust 
or portion of a trust which is not described in 
subparagraph (A), any property which is 
attributable to a gratuitous transfer of assets 
by an individual who is subject to tax under 
this chapter for the calendar year shall be 
treated as property of such individual and not 
as property of the trust.
``(ii) Other trusts.--
``(I) In general.--In the case of 
any trust or portion of a trust which 
is described in subclause (II), the 
property of such trust shall be treated 
as the property of the beneficiary of 
such trust and not as the property of 
the trust.
``(II) Trusts to which this 
subclause applies.--A trust is 
described in this subclause if such 
trust not described in subparagraph 
(A), the assets of such trust are not 
attributable to a gratuitous transfer 
of assets by a person who is subject to 
tax under this chapter for the calendar 
year, and such trust has a single 
beneficiary (determined as of the last 
day of the calendar year).
``(C) Right of recovery.--
``(i) In general.--If any part of the net 
value of taxable assets of an individual on 
which tax has been paid consists of the value 
of property held by a trust which is included 
in the net value of taxable assets of such 
individual by reason of subparagraph (B), then 
such individual shall be entitled to recover 
from the trust the amount which bears the same 
ratio to the recoverable amount as--
``(I) the value of such property, 
bears to
``(II) the net value of taxable 
assets of the taxpayer.
``(ii) Recoverable amount.--For purposes of 
clause (i), the recoverable amount with respect 
to any trust is the excess of--
``(I) the tax imposed under this 
chapter for the calendar year on the 
individual, over
``(II) the amount of such tax which 
would be imposed for such calendar year 
on such individual if no property held 
by such trust were included in the net 
value of taxable assets of the 
individual.
``(iii) Treatment where no recovery.--In 
any case where a trust does not reimburse any 
taxpayer as provided in clause (i), the 
taxpayer shall be treated for purposes of this 
chapter as having made a gratuitous transfer to 
the trust in an amount equal to the amount 
determined under clause (i). Such transfer 
shall be treated as having been made on the 
last day of the calendar year for which the tax 
under subsection (a) was due.
``(4) Treatment of assets held by certain split-interest 
trusts.--
``(A) Remainder interests in charitable remainder 
annuity trusts and charitable remainder unitrusts.--In 
the case of any charitable remainder annuity trust (as 
defined in section 664(d)(1)) or of a charitable 
remainder unitrust (as defined in section 664(d)(2))--
``(i) the present value of any remainder 
interest shall not be taken into account under 
subsection (a), and
``(ii) the present value of any other 
interests shall be taken in account under 
subsection (a), in accordance with regulations 
promulgated by the Secretary, as the property 
of the beneficiaries of such interests.
``(B) Charitable lead annuity trusts and charitable 
lead unitrusts.--In the case of a charitable lead 
annuity trust (as defined in section 2642(e)(3)) or a 
charitable lead unitrust--
``(i) the present value of any interest 
described in section 2522(c)(2)(B) shall not be 
taken into account under subsection (a), and
``(ii) notwithstanding paragraphs (A) and 
(B) of paragraph (3), the present value of any 
remainder interest shall be taken into account 
under subsection (a), in accordance with 
regulations promulgated by the Secretary, as 
the property of the beneficiaries of such 
remainder interest.
``(d) Establishment of Valuation Rules.--Not later than 12 months 
after the date of the enactment of this section, the Secretary shall 
establish rules and methods for determining the value of any asset for 
purposes of this subtitle, including rules for the valuation of assets 
that are not publicly traded or that do not have a readily 
ascertainable value. Such rules and methods--
``(1) may utilize retrospective and prospective formulaic 
valuation methods not currently in use by the Secretary,
``(2) may require the use of formulaic valuation approaches 
for designated assets, including formulaic approaches based on 
proxies for determining presumptive valuations, formulaic 
approaches based on prospective adjustments from purchase 
prices or other prior events, or formulaic approaches based on 
retrospectively adding deferral charges based on eventual sale 
prices or other specified later events indicative of valuation, 
and
``(3) may address the use of valuation discounts.

``SEC. 2903. SPECIAL RULES.

``(a) Deceased Individuals.--
``(1) In general.--In the case of any individual who dies 
during a calendar year and who is not married on the date of 
such individual's death--
``(A) section 2901(a) shall be applied by 
substituting `the date of the individual's death' for 
`the last day of the calendar year', and
``(B) the amount of the tax imposed under such 
section shall be reduced by an amount which bears the 
same ratio to such amount (determined without regard to 
this subsection) as--
``(i) the number of days in the calendar 
year after the date of the individual's death, 
bears to
``(ii) 365.
``(2) Coordination with estate tax.--For purposes of 
section 2053, the tax imposed by this section for the year of 
the decedent's death shall be considered to have been imposed 
before such death.
``(b) Application to Non-Residents.--In the case of any individual 
who is a non-resident and not a citizen of the United States, this 
subtitle shall apply only to the property of such individual which is 
situated in the United States (determined under rules similar to the 
rules under subchapter B of chapter 11).
``(c) Application to Covered Expatriates.--In the case of an 
individual who is a covered expatriate (as defined in section 877A), 
section 2901(a) shall be applied--
``(1) as if the calendar year ended on the day before the 
expatriation, and
``(2) as if the rate of tax under both subparagraphs (A) 
and (B) of section 2901(b)(1) were 40 percent.

``SEC. 2904. INFORMATION REPORTING.

``(a) In General.--Not later than 12 months after the date of the 
enactment of this section, the Secretary shall by regulations require 
the reporting of any information concerning the net value of assets 
appropriate to enforce the tax imposed by this chapter.
``(b) Method of Reporting.--The Secretary shall, where appropriate, 
require the reporting made under subsection (a) to be made as a part of 
existing income reporting requirements (including requirements under 
chapter 4 (relating to taxes to enforce reporting on certain foreign 
accounts)).
``(c) Responsibility for Reporting.--The Secretary may impose 
reporting obligations by reference to the ownership, control, 
management, claim to income from, or other relationship to assets and 
liabilities for purposes of administering the tax imposed by this 
section and may impose such obligations on financial institutions, 
business entities, or other persons, including requiring business 
entities to provide estimates of the value of the entity itself.

``SEC. 2905. ENFORCEMENT.

``The Secretary shall annually audit not less than 30 percent of 
taxpayers required to pay the tax imposed under this chapter.''.
(b) No Deduction From Income Taxes.--Section 275 of the Internal 
Revenue Code of 1986 is amended by inserting after paragraph (6) the 
following new paragraph:
``(7) Taxes imposed by chapter 18.''.
(c) Extension of Time for Payment of Tax.--
(1) In general.--Section 6161(a) of the Internal Revenue 
Code of 1986 is amended by adding at the end the following new 
paragraph:
``(3) Wealth tax.--
``(A) In general.--In the case of taxpayer 
described in subparagraph (B), the Secretary may extend 
the time for payment of the tax imposed under chapter 
18 for a reasonable period not to exceed 5 years from 
the date fixed for the payment thereof.
``(B) Taxpayers described.--A taxpayer is described 
in this subparagraph if such the Secretary determines--
``(i) the taxpayer has severe liquidity 
constraints, or
``(ii) immediate payment would cause undue 
hardship on an ongoing enterprise.''.
(2) Rules.--Not later than 12 months after the date of the 
enactment of this Act, the Secretary of the Treasury (or the 
Secretary's delegate) shall establish rules for the application 
of the amendments made by paragraph (1).
(d) Application of Accuracy Related Penalties.--
(1) In general.--Section 6662(b) of the Internal Revenue 
Code of 1986 is amended by adding at the end the following new 
paragraph:
``(11) Any substantial wealth tax valuation 
understatement.''.
(2) Substantial wealth tax understatement.--Section 6662 of 
such Code is amended by adding at the end the following new 
subsection:
``(n) Application to Substantial Wealth Tax Valuation 
Understatement.--
``(1) Substantial wealth tax valuation understatement 
defined.--
``(A) In general.--For purposes of this section, 
there is a substantial wealth tax valuation 
understatement if the value of any property claimed on 
any return of tax imposed by subtitle B-1 is 65 percent 
or less of the amount determined to be the correct 
amount of such valuation.
``(B) Limitation.--No penalty shall be imposed by 
reason of subsection (b)(11) unless the portion of the 
underpayment attributable to substantial wealth tax 
valuation understatements for the calendar year exceeds 
$5,000.
``(2) Increased penalty.--
``(A) In general.--In the case of any portion of an 
underpayment which is attributable to one or more 
substantial wealth tax valuation understatement, 
subsection (a) shall be applied--
``(i) in the case of a substantial wealth 
tax valuation understatement which is a gross 
wealth tax valuation misstatement, by 
substituting `50 percent' for `20 percent', and
``(ii) in any other case, by substituting 
`30 percent' for `20 percent'.
``(B) Gross wealth tax valuation misstatement.--For 
purposes of subparagraph (A), the term `gross wealth 
tax valuation misstatement' means a substantial wealth 
tax valuation understatement, as determined under 
paragraph (1) by substituting `40 percent' for `65 
percent'.''.
(e) Clerical Amendment.--The table of subtitles of such Code is 
amended by inserting after the item relating to subtitle B the 
following new item:

``Subtitle B-1--Wealth Tax''.

(f) Effective Date.--The amendments made by this section shall 
apply to calendar years beginning after December 31, 2026.
(g) Periodic Reports.--Not later than January 1, 2029, and every 2 
years thereafter, the Secretary of the Treasury (or the Secretary's 
delegate) shall submit to Congress a report on the tax imposed under 
chapter 18 of the Internal Revenue Code of 1986 (as added by this Act), 
including any issues related to the administration and enforcement of 
such tax.

SEC. 3. STRENGTHENING DISCLOSURE REQUIREMENTS.

(a) Regulatory Authority.--The Secretary of the Treasury (or the 
Secretary's delegate) may issue such rules and regulations as necessary 
to prevent taxpayers from avoiding the purpose of information reporting 
requirements under the Internal Revenue Code of 1986 by placing assets 
in any foreign corporation, partnership, or trust in which the taxpayer 
holds directly or indirectly, a significant interest as the sole or 
principal owner or the sole or principal beneficial owner.
(b) FATCA Enforcement Plan.--The Secretary of the Treasury (or the 
Secretary's delegate) shall develop a comprehensive plan for managing 
efforts to leverage data collected under chapter 4 of the Internal 
Revenue Code of 1986 in agency compliance efforts. Such plan shall 
include an evaluation of the extent to which actions being undertaken 
as of the date of the enactment of this Act for the enforcement of the 
requirements of such chapter improve voluntary compliance and address 
noncompliance with such requirements.

SEC. 4. INTERNAL REVENUE SERVICE FUNDING.

(a) In General.--Subchapter A of chapter 80 of the Internal Revenue 
Code of 1986 is amended by adding at the end the following new section:

``SEC. 7813. AUTHORIZATION OF APPROPRIATIONS.

``There are authorized to be appropriated to the Secretary for the 
period of fiscal years 2027 through 2037--
``(1) for enforcement of this title, $70,000,000,000,
``(2) for taxpayer services, $10,000,000,000, and
``(3) for business system modernization, 
$20,000,000,000.''.
(b) Clerical Amendment.--The table of sections for subchapter A of 
chapter 80 of the Internal Revenue Code of 1986 is amended by adding at 
the end the following new item:

``Sec. 7813. Authorization of appropriations.''.
<all>