H.R. 8294

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 8294 Introduced in House (IH)]

<DOC>

119th CONGRESS
2d Session
H. R. 8294

To amend the Internal Revenue Code of 1986 to impose a surtax on high 
income individuals.

_______________________________________________________________________

IN THE HOUSE OF REPRESENTATIVES

April 15, 2026

Mr. Beyer (for himself, Mr. Cohen, Mr. Deluzio, Ms. Norton, Ms. Tlaib, 
and Mr. Davis of Illinois) 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 surtax on high 
income individuals.

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 ``Millionaires Surtax Act''.

SEC. 2. SURCHARGE ON HIGH INCOME INDIVIDUALS.

(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--SURCHARGE ON HIGH INCOME INDIVIDUALS

``Sec. 59B. Surcharge on high income individuals.

``SEC. 59B. SURCHARGE ON HIGH INCOME INDIVIDUALS.

``(a) General Rule.--In the case of a taxpayer other than a 
corporation, there is hereby imposed (in addition to any other tax 
imposed by this subtitle) a tax equal to 10 percent of so much of the 
modified adjusted gross income of the taxpayer as exceeds $2,000,000.
``(b) Taxpayers Not Making a Joint Return.--In the case of any 
taxpayer other than a taxpayer making a joint return under section 6013 
or a surviving spouse (as defined in section 2(a)), subsection (a) 
shall be applied by substituting `$1,000,000' for `$2,000,000'.
``(c) Modified Adjusted Gross Income.--For purposes of this 
section, the term `modified adjusted gross income' means adjusted gross 
income reduced by any deduction (not taken into account in determining 
adjusted gross income) allowed for investment interest (as defined in 
section 163(d)). In the case of an estate or trust, adjusted gross 
income shall be determined as provided in section 67(e).
``(d) Special Rules.--
``(1) Nonresident alien.--In the case of a nonresident 
alien individual, only amounts taken into account in connection 
with the tax imposed under section 871(b) shall be taken into 
account under this section.
``(2) Citizens and residents living abroad.--The dollar 
amount in effect under subsection (a) (after the application of 
subsection (b)) shall be decreased by the excess of--
``(A) the amounts excluded from the taxpayer's 
gross income under section 911, over
``(B) the amounts of any deductions or exclusions 
disallowed under section 911(d)(6) with respect to the 
amounts described in subparagraph (A).
``(3) Charitable trusts.--Subsection (a) shall not apply to 
a trust all the unexpired interests in which are devoted to one 
or more of the purposes described in section 170(c)(2)(B).
``(4) 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 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--Surcharge on High Income Individuals''.

(c) Section 15 Not To Apply.--The amendment made by subsection (a) 
shall not be treated as a change in a rate of tax for purposes of 
section 15 of the Internal Revenue Code of 1986.
(d) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2026.
<all>