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Bill
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Billionaires Income Tax Act

S. 3367 · 118th Congress · Nov 30, 2023 · Lineage

A BILL

To amend the Internal Revenue Code of 1986 to eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as buy, borrow, die, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes.

Section 1 Short title; amendment of 1986 Code; table of contents

(a)
Short Title— This Act may be cited as the “Billionaires Income Tax Act”.
(b)
Amendment of 1986 Code— Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.
(c)
Table of contents— The table of contents of this Act is as follows:

Sec. 2 Purpose

The purpose of this Act is to require billionaires to pay taxes annually by eliminating the ability of high income and high net worth taxpayers to use tax planning strategies such as “buy, borrow, die” to defer paying taxes indefinitely, specifically by—
(1)
under the provisions of title I of this Act—
(A)
requiring high income and high net worth taxpayers to pay tax on the income they earn on an annual basis, just like working people do on their income from wages, through mark-to-market taxation, and
(B)
shutting down the ability of the ultra wealthy to buy and hold appreciating assets and borrow against those assets to support their lavish lifestyles, all completely tax-free, and
(2)
under the provisions of title II of this Act, closing loopholes in the tax code that allow high income and high net worth taxpayers to shield their income from taxation, including the loophole that allows ultra wealthy taxpayers to transfer untaxed appreciated assets to their heirs at death and such heirs to sell such assets completely tax-free.