Congress Proposes 'Billionaires Income Tax' to Tax Unrealized Gains and End Wealthy Tax Loopholes
Stalled
No legislative action in over 90 days.
Billionaire small business owners would face a deferral recapture charge with interest when they sell or transfer their privately held businesses, since private companies count as nontradable covered assets. The bill also eliminates the Section 1202 exclusion for gains on qualified small business stock for applicable taxpayers who acquire such stock after November 30, 2025, removing a tax benefit that encourages investment in small businesses by the ultra-wealthy.
Referred to the House Committee on Ways and Means.
Introduced in House
The bill was officially filed and given a number. It now enters the legislative queue.
Sponsor introductory remarks on measure. (CR H4397)
Sponsor introductory remarks on measure. (CR E863)
No votes have been recorded for this legislation yet.
A bicameral group of Democrats introduced the Billionaires Income Tax (BIT) Act on September 17, 2025. The proposal requires individuals with over $100 million in annual income or $1 billion in assets to pay tax each year on the appreciation of tradable assets using mark-to-market rules.
Senator Ron Wyden reintroduced the Billionaires Income Tax Act in September 2025 with first-time companion legislation in the House. The bill targets annual unrealized gains for the ultra-wealthy, but faces potential constitutional hurdles regarding the definition of 'direct taxes.'
This in-depth analysis explores the 'buy, borrow, die' strategy that Senator Ron Wyden's Billionaires Income Tax Act aims to eliminate. It explains how billionaires use asset-backed loans to fund their lifestyles tax-free and avoid capital gains taxes through stepped-up basis at death.
Document Type
Congressional Bill
Official Title
Billionaires Income Tax Act
Analysis generated by AI. Always verify with official sources.