Ultra-Millionaire Tax Act of 2026

Key Points

• The bill creates a brand new annual tax on wealth, not income. It applies to the total value of everything a person owns, including stocks, real estate, and other assets worldwide, minus any debts. This marks a fundamental shift from how the U.S. has traditionally taxed people.
• People with assets between $50 million and $1 billion would pay 2% per year on the amount above $50 million. Those with over $1 billion would pay 3% on the amount above that threshold. If the U.S. ever passes a universal healthcare program that bans private duplicate coverage, the billionaire rate doubles to 6%.
• To prevent people from renouncing their citizenship to dodge the tax, the bill imposes a 40% exit tax on all wealth for covered expatriates. This is far higher than the regular 2-3% annual rate and is designed to make fleeing the country financially painful.
• The IRS would get a massive funding boost of $100 billion over 11 years: $70 billion for enforcement, $10 billion for taxpayer services, and $20 billion for technology upgrades. The agency would also be required to audit at least 30% of wealth tax filers every year.
• The bill includes anti-avoidance rules for trusts and gifts to minor family members. Wealthy individuals cannot simply transfer assets to trusts or children under 18 to escape the tax. The Treasury must also create new valuation rules within 12 months for hard-to-value assets like private businesses.
• The tax would take effect for calendar years starting after December 31, 2026, giving the Treasury about a year to write the regulations and valuation methods needed to implement it. Reports to Congress on the tax's administration would be due every two years starting January 1, 2029.

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