HR8085119th CongressWALLET

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.

Show full summary
  • 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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