Congress·In Committee·H.R. 5427

Congress Proposes 'Billionaires Income Tax' to Tax Unrealized Gains and End Wealthy Tax Loopholes

Billionaires Income Tax Act

6 months ago·View on Congress.gov

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Stalled

No legislative action in over 90 days.

Legislative Progress

House

Senate

President

Law

Key Points

This bill would require the ultra-wealthy to pay taxes every year on the increased value of their investments, such as stocks and real estate, even if they do not sell them. This is known as 'mark-to-market' taxation, which treats the growth of wealth more like a regular paycheck that is taxed annually.
The rules specifically target 'applicable taxpayers,' defined as individuals who have more than $1 billion in assets or earn more than $100 million in income for three consecutive years. It also applies to certain high-value trusts and estates.
The policy aims to end a strategy called 'buy, borrow, die.' This is where billionaires buy assets that grow in value, borrow money against those assets to fund their lifestyles tax-free, and then pass the assets to heirs at death without ever paying capital gains taxes.
For assets that are difficult to value every year, like private companies or certain real estate, the tax is paid when the asset is eventually sold. However, an extra interest charge is added to the tax bill to make up for the years the payment was delayed.
The bill would treat assets given as gifts or passed down at death as if they were sold for their current market value. This means the person giving the asset (or their estate) must pay taxes on the profit at that time, preventing large fortunes from being passed to heirs tax-free.
If passed, these new tax requirements would take effect for the tax year beginning January 1, 2026. The bill also includes new reporting requirements for banks and investment firms to help the government track the wealth of these individuals.

TaxesEconomy Finance

Impact Analysis

Personal Impact

Who is affectedScoreImpactCertaintyScopeDurationSentiment

Scores: 1 = low, 5 = highSentiment: -5 to +5 (net benefit)

Milestones

2 milestones4 actions

Sep 17, 2025House

Referred to the House Committee on Ways and Means.

Sep 17, 2025

Introduced in House

Sep 17, 2025

Sponsor introductory remarks on measure. (CR H4397)

Sep 16, 2025

Sponsor introductory remarks on measure. (CR E863)

Related News

3 articles

Thomson Reuters·6 months ago

Dems, Advocacy Orgs Announce Billionaire Tax Plan

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.

Bloomberg Tax·3 months ago

Revival of the Wealth Tax May Prompt Constitutional Challenges

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.'

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The Atlantic·over 4 years ago

Buy, Borrow, Die: How to be a billionaire and pay no 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.

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