Ultra-Millionaire Tax Act of 2026
Sponsored By: Representative Jayapal
Introduced
Summary
Would establish an annual wealth tax on ultra-high net worth individuals. It would measure net assets each year and create new rules for valuation, reporting, and enforcement while funding major IRS work over a decade.
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- Ultra-wealthy households: Would tax net assets above $50 million, applying 2% on value between $50 million and $1 billion and a top rate that is 3% or 6% on amounts above $1 billion depending on whether qualifying universal health legislation is in effect.
- Trusts and beneficiaries: Would treat certain nongrantor multibeneficiary trusts as individual taxpayers and let the Treasury set rules for how zero-bracket amounts and top-bracket amounts are allocated and carried forward among beneficiaries.
- Tax administration and enforcement: Would authorize $70 billion for enforcement, $10 billion for taxpayer services, and $20 billion for business system modernization for fiscal years 2027–2037. It would require the Treasury to audit at least 30% of wealth taxpayers annually, develop a FATCA enforcement plan, expand anti-avoidance rules, create steep penalties for valuation understatements, and allow up to 5 years of payment relief for qualifying liquidity hardships.
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Bill Overview
Analyzed Economic Effects
8 provisions identified: 2 benefits, 5 costs, 1 mixed.
High tax on covered expatriates
If enacted, covered expatriates would be taxed at a 40% rate for the wealth tax and the tax year would end the day before expatriation for valuation purposes. This rule would apply for calendar years beginning after December 31, 2026.
New annual wealth tax for ultra-rich
If enacted, individuals would face a new annual tax on net assets measured on the last day of the year. No tax would apply to net assets up to $50 million. A 2% tax would apply to assets between $50 million and $1 billion. Assets above $1 billion would face an extra 3% tax, or 6% in any year a federal universal health program that bans duplicate private benefits is in effect. Married couples would be treated as one taxpayer. Small personal items worth $50,000 or less would be excluded. The rule would start for calendar years after December 31, 2026.
New trust and family transfer rules
If enacted, the bill would treat many trust assets and some family gifts as the taxpayer's property for the wealth tax. Gifts to family members under age 18 made after enactment would be treated as the transferor's property until the child turns 18. Grantor-trust assets would be treated as owned by the grantor. Many nongrantor multibeneficiary trusts would be taxed like individuals and would receive zero- and 2% bracket amounts based on beneficiaries' unused amounts, with a default of $0 if beneficiaries do not assign amounts. Treasury would write rules for charitable split-interest trusts and other details. These rules would apply for years after December 31, 2026.
Wealth tax not deductible on returns
If enacted, taxpayers could not deduct wealth taxes paid from their income tax returns. That change would start for calendar years after December 31, 2026.
Large IRS funding for wealth tax
If enacted, the bill would authorize $70 billion for enforcement, $10 billion for taxpayer services, and $20 billion for IRS business system modernization for fiscal years 2027 through 2037. The funding would support enforcement, audits, taxpayer help, and IT upgrades to run the new wealth tax.
Payment relief and death-year rules
If enacted, the Treasury Secretary could let taxpayers delay paying the wealth tax for up to 5 years if they have severe liquidity problems or if immediate payment would unduly hurt an ongoing business. The Treasury must write rules within 12 months after enactment. If an individual dies during the year, assets would be valued on the date of death and that year's wealth tax would be reduced by the number of days after death divided by 365. The tax for the year of death would be treated as imposed before death for estate tax coordination.
Stronger audits, penalties, and reporting
If enacted, the IRS would have to audit at least 30% of taxpayers who pay the wealth tax each year. Treasury must issue rules within 12 months requiring institutions to report asset information needed to enforce the tax and may link this to current reporting systems. Penalties for valuation understatements would increase: a 30% penalty for substantial understatements (claimed value 65% or less of correct value) and 50% for gross misstatements (40% or less), and no penalty under this rule would apply unless the underpayment from those understatements exceeds $5,000. The Treasury must also report to Congress by Jan. 1, 2029, and every two years after that on administration and enforcement.
Nonresidents taxed only on U.S. property
If enacted, nonresident noncitizens would be taxed only on property located in the United States. Treasury would determine what counts as U.S.-situated property using rules like those in existing law. This rule would apply for calendar years after December 31, 2026.
Sponsors & CoSponsors
Sponsor
Jayapal
WA • D
Cosponsors
Boyle (PA)
PA • D
Sponsored 3/25/2026
Ansari
AZ • D
Sponsored 3/25/2026
Beyer
VA • D
Sponsored 3/25/2026
Chu
CA • D
Sponsored 3/25/2026
Davis (IL)
IL • D
Sponsored 3/25/2026
Dean (PA)
PA • D
Sponsored 3/25/2026
Deluzio
PA • D
Sponsored 3/25/2026
DeSaulnier
CA • D
Sponsored 3/25/2026
Foushee
NC • D
Sponsored 3/25/2026
Friedman
CA • D
Sponsored 3/25/2026
Frost
FL • D
Sponsored 3/25/2026
Garcia (IL)
IL • D
Sponsored 3/25/2026
Garcia (CA)
CA • D
Sponsored 3/25/2026
Goldman (NY)
NY • D
Sponsored 3/25/2026
Grijalva
AZ • D
Sponsored 3/25/2026
Ivey
MD • D
Sponsored 3/25/2026
Jackson (IL)
IL • D
Sponsored 3/25/2026
Johnson (GA)
GA • D
Sponsored 3/25/2026
Kelly (IL)
IL • D
Sponsored 3/25/2026
Lee (PA)
PA • D
Sponsored 3/25/2026
McGovern
MA • D
Sponsored 3/25/2026
Nadler
NY • D
Sponsored 3/25/2026
Del. Norton, Eleanor Holmes [D-DC-At Large]
DC • D
Sponsored 3/25/2026
Ocasio-Cortez
NY • D
Sponsored 3/25/2026
Omar
MN • D
Sponsored 3/25/2026
Pallone
NJ • D
Sponsored 3/25/2026
Pressley
MA • D
Sponsored 3/25/2026
Ramirez
IL • D
Sponsored 3/25/2026
Sanchez
CA • D
Sponsored 3/25/2026
Schakowsky
IL • D
Sponsored 3/25/2026
Simon
CA • D
Sponsored 3/25/2026
Smith (WA)
WA • D
Sponsored 3/25/2026
Stansbury
NM • D
Sponsored 3/25/2026
Takano
CA • D
Sponsored 3/25/2026
Thanedar
MI • D
Sponsored 3/25/2026
Tlaib
MI • D
Sponsored 3/25/2026
Tokuda
HI • D
Sponsored 3/25/2026
Velazquez
NY • D
Sponsored 3/25/2026
Watson Coleman
NJ • D
Sponsored 3/25/2026
Roll Call Votes
No roll call votes available for this bill.
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