# 119-hr-5427: Billionaires Income Tax Act 119-hr-5427, Billionaires Income Tax Act, is a 119th Congress bill sponsored by Rep. Cohen, Steve [D-TN-9] (D-TN); status introduced; PRIA reads it as touching household money (as of 2026-10-08). - Canonical: https://policyrisk.com/legislation/119-hr-5427 - As of: 2026-10-08 - Plain-text twin of the page above; the HTML and this file carry the same facts. ## Facts - Bill: 119-hr-5427 - Congress: 119 - Title: Billionaires Income Tax Act - Status: introduced - Introduced: 2025-09-17 - Sponsor: Rep. Cohen, Steve [D-TN-9] (D-TN) - Cosponsors: 33 - Policy area: Taxation - Touches household money: yes - Last recorded action: 2026-10-08 ## Summary **Elimination of tax deferral for applicable taxpayers.** This bill would require many very wealthy individuals, certain trusts, and designated entities to recognize gains each year on tradable assets and treat many transfers of nontradable assets as taxable sales. - Individuals and households: People who meet a three‑year income test of applicable adjusted gross income over $100 million or an asset test of over $1 billion would become "applicable taxpayers" and face annual mark‑to‑market treatment on tradable covered assets. Nontradable assets would use an "applicable value" test based on cost, adjusted basis, recent financial statements, or other Secretary‑prescribed methods. - Pass‑through entities and owners: Partnerships, S corporations, and similar entities would face new, ongoing reporting and cross‑entity notice rules that pass gains and required disclosures up and down ownership chains. A "significant owner" is defined as a 5 percent owner or any owner whose nontradable interests exceed $50 million, and certain entity elections are irrevocable without IRS consent. - Deferred pay, insurance, and investor breaks: The bill creates a deferral recapture charge that includes interest and is capped at 49 percent of the gain and it adds new reporting for large deferred compensation payments over $5 million. It also tightens rules for private‑placement life insurance and annuities, limits the qualified small business stock exclusion for post‑Nov. 30, 2025 sales, and narrows Qualified Opportunity Fund benefits for applicable taxpayers. ## Cosponsors (33) - Rep. Beyer, Donald S. [D-VA-8] (D-VA), 2025-09-17T00:00:00.000Z - Rep. Tlaib, Rashida [D-MI-12] (D-MI), 2025-09-17T00:00:00.000Z - Rep. García, Jesús G. "Chuy" [D-IL-4] (D-IL), 2025-09-17T00:00:00.000Z - Rep. McGovern, James P. [D-MA-2] (D-MA), 2025-09-17T00:00:00.000Z - Del. Norton, Eleanor Holmes [D-DC-At Large] (D-DC), 2025-09-17T00:00:00.000Z - Rep. Davis, Danny K. [D-IL-7] (D-IL), 2025-09-17T00:00:00.000Z - Rep. DeLauro, Rosa L. [D-CT-3] (D-CT), 2025-09-17T00:00:00.000Z - Rep. Boyle, Brendan F. [D-PA-2] (D-PA), 2025-09-17T00:00:00.000Z - Rep. McCollum, Betty [D-MN-4] (D-MN), 2025-09-17T00:00:00.000Z - Rep. Nadler, Jerrold [D-NY-12] (D-NY), 2025-09-17T00:00:00.000Z - Rep. Garamendi, John [D-CA-8] (D-CA), 2025-09-17T00:00:00.000Z - Rep. Kelly, Robin L. [D-IL-2] (D-IL), 2025-09-17T00:00:00.000Z - Rep. Dean, Madeleine [D-PA-4] (D-PA), 2025-09-17T00:00:00.000Z - Rep. Mullin, Kevin [D-CA-15] (D-CA), 2025-09-17T00:00:00.000Z - Rep. Omar, Ilhan [D-MN-5] (D-MN), 2025-09-17T00:00:00.000Z - Rep. Landsman, Greg [D-OH-1] (D-OH), 2025-09-17T00:00:00.000Z - Rep. Scanlon, Mary Gay [D-PA-5] (D-PA), 2025-09-17T00:00:00.000Z - Rep. Clarke, Yvette D. [D-NY-9] (D-NY), 2025-09-17T00:00:00.000Z - Rep. Huffman, Jared [D-CA-2] (D-CA), 2025-09-17T00:00:00.000Z - Rep. Norcross, Donald [D-NJ-1] (D-NJ), 2025-09-17T00:00:00.000Z - Rep. Sánchez, Linda T. [D-CA-38] (D-CA), 2025-09-17T00:00:00.000Z - Rep. Evans, Dwight [D-PA-3] (D-PA), 2025-09-17T00:00:00.000Z - Rep. Frost, Maxwell [D-FL-10] (D-FL), 2025-09-17T00:00:00.000Z - Rep. Lee, Summer L. [D-PA-12] (D-PA), 2025-09-17T00:00:00.000Z - Rep. Simon, Lateefah [D-CA-12] (D-CA), 2025-09-17T00:00:00.000Z - Rep. Jackson, Jonathan L. [D-IL-1] (D-IL), 2025-09-17T00:00:00.000Z - Rep. Ramirez, Delia C. [D-IL-3] (D-IL), 2025-09-17T00:00:00.000Z - Rep. Chu, Judy [D-CA-28] (D-CA), 2026-02-09T00:00:00.000Z - Rep. Lofgren, Zoe [D-CA-18] (D-CA), 2026-02-09T00:00:00.000Z - Rep. Budzinski, Nikki [D-IL-13] (D-IL), 2026-02-23T00:00:00.000Z - Rep. Larson, John B. [D-CT-1] (D-CT), 2026-02-23T00:00:00.000Z - Rep. Deluzio, Christopher R. [D-PA-17] (D-PA), 2026-02-23T00:00:00.000Z - Rep. Dexter, Maxine [D-OR-3] (D-OR), 2026-06-24T00:00:00.000Z ## Provisions PRIA read - Extra taxes on big deferred pay: cost, high. If enacted, applicable taxpayers would owe an added tax on nonqualified deferred pay, capped at 10% of the includible amount, plus an extra 10% tax on severance pay. Payers who make more than $5,000,000 of deferred pay or severance to a person would have to file an IRS return and give the person a… - Gifts, death, and trusts taxed: cost, high. If enacted, transfers of covered assets by gift, at death, or into certain trusts by an applicable taxpayer would be treated like a sale at fair market value. Nontradable assets sold or transferred would face a deferral recapture tax that spreads the gain over the holding period, uses prior years’… - Investment tax without income cap: cost, high. If you are an applicable taxpayer, the Net Investment Income Tax would apply without the usual adjusted gross income threshold. More of your investment income would be subject to this tax in any year you are treated as applicable. This would apply for years beginning after December 31, 2025. - Private‑placement insurance taxed more: cost, high. If enacted, amounts from private‑placement life insurance or annuity contracts held by applicable taxpayers would be taxed under new rules. Certain distributions would face an extra 10% tax, and death benefits from these contracts would not be excluded from income. Insurers and reinsurers would hav… - QSBS exclusion ends for billionaires: cost, high. Applicable taxpayers would lose the qualified small business stock (QSBS) gain exclusion for sales on or after November 30, 2025, unless the stock was acquired before that date. The provision also would tax certain private‑placement death benefits received in years beginning after December 31, 2025… - Opportunity Zone breaks limited: cost, medium. For applicable taxpayers, the bill would curb Qualified Opportunity Fund tax benefits. Deferral elections could end after the earlier of December 31, 2026, or the last day of the year before you first become applicable (with a special November 30, 2025 date for some 2025 cases). The 10‑year basis s… - New rules for pass‑through entities: cost, medium. Partnerships, S‑corps, and similar entities could elect to be treated like applicable taxpayers for tradable‑asset events, and that choice would generally be irrevocable without IRS consent. When an IRS notice is in effect, entities would need to report detailed gain/loss shares and holding periods… - Annual tax on tradable gains: mixed, high. Applicable taxpayers would have to mark tradable assets to market when a taxable event happens and count gains or losses as if sold at fair market value. The bill defines what is tradable, how assets are valued, and when conversions between tradable and nontradable assets trigger tax. Qualified Opp… - First‑year election and 5‑year payments: mixed, high. In your first year as an applicable taxpayer, you could elect to treat certain nontradable assets as tradable and then pay the first‑year tax over five equal annual installments. You must make the election by the return due date. Selling an elected asset, death, bankruptcy, or missing a payment cou… - Who this tax would cover: mixed, high. This bill would set who is treated as an “applicable taxpayer.” For each of the past 3 years, you would need over $100 million in income (or $50 million if married filing separately) or over $1 billion in assets (or $500 million if married filing separately). For non‑grantor trusts, the tests would… ## Related bills - 119-hr-7973: Momnibus Act - 119-hr-51: Washington, D.C. Admission Act - 119-hr-20: Richard L. Trumka Protecting the Right to Organize Act of 2025 - 119-hr-5390: FAMILY Act - 119-hr-15: Equality Act - 119-hr-1589: American Dream and Promise Act of 2025 ## Sources - [119-hr-5427 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/5427) ## Related - [119-hr-7973: Momnibus Act](https://policyrisk.com/legislation/119-hr-7973) - [119-hr-51: Washington, D.C. Admission Act](https://policyrisk.com/legislation/119-hr-51) - [119-hr-20: Richard L. Trumka Protecting the Right to Organize Act of 2025](https://policyrisk.com/legislation/119-hr-20) - [119-hr-5390: FAMILY Act](https://policyrisk.com/legislation/119-hr-5390) - [119-hr-15: Equality Act](https://policyrisk.com/legislation/119-hr-15) - [119-hr-1589: American Dream and Promise Act of 2025](https://policyrisk.com/legislation/119-hr-1589) - [All bills in Congress](https://policyrisk.com/legislation) Source: PRIA, https://policyrisk.com/legislation/119-hr-5427 (as of 2026-10-08).