# 119-s-2845: Billionaires Income Tax Act 119-s-2845, Billionaires Income Tax Act, is a 119th Congress bill sponsored by Sen. Wyden, Ron [D-OR] (D-OR); status introduced; PRIA reads it as touching household money (as of 2026-10-08). - Canonical: https://policyrisk.com/legislation/119-s-2845 - As of: 2026-10-08 - Plain-text twin of the page above; the HTML and this file carry the same facts. ## Facts - Bill: 119-s-2845 - Congress: 119 - Title: Billionaires Income Tax Act - Status: introduced - Introduced: 2025-09-17 - Sponsor: Sen. Wyden, Ron [D-OR] (D-OR) - Cosponsors: 23 - Policy area: Taxation - Touches household money: yes - Last recorded action: 2026-10-08 ## Summary **Creates an annual tax regime for very wealthy individuals by treating many holdings as if sold each year to stop "buy, borrow, die" deferral.** It would mark tradable assets to market, force tax on transfers of nontradable assets, and add wide reporting and anti‑avoidance rules for entities and trusts. ## Cosponsors (23) - Sen. Whitehouse, Sheldon [D-RI] (D-RI), 2025-09-17T00:00:00.000Z - Sen. Warren, Elizabeth [D-MA] (D-MA), 2025-09-17T00:00:00.000Z - Sen. Sanders, Bernard [I-VT] (I-VT), 2025-09-17T00:00:00.000Z - Sen. Smith, Tina [D-MN] (D-MN), 2025-09-17T00:00:00.000Z - Sen. Luján, Ben Ray [D-NM] (D-NM), 2025-09-17T00:00:00.000Z - Sen. Welch, Peter [D-VT] (D-VT), 2025-09-17T00:00:00.000Z - Sen. Alsobrooks, Angela D. [D-MD] (D-MD), 2025-09-17T00:00:00.000Z - Sen. Baldwin, Tammy [D-WI] (D-WI), 2025-09-17T00:00:00.000Z - Sen. Blumenthal, Richard [D-CT] (D-CT), 2025-09-17T00:00:00.000Z - Sen. Duckworth, Tammy [D-IL] (D-IL), 2025-09-17T00:00:00.000Z - Sen. Fetterman, John [D-PA] (D-PA), 2025-09-17T00:00:00.000Z - Sen. Heinrich, Martin [D-NM] (D-NM), 2025-09-17T00:00:00.000Z - Sen. Hirono, Mazie K. [D-HI] (D-HI), 2025-09-17T00:00:00.000Z - Sen. Markey, Edward J. [D-MA] (D-MA), 2025-09-17T00:00:00.000Z - Sen. Merkley, Jeff [D-OR] (D-OR), 2025-09-17T00:00:00.000Z - Sen. Murphy, Christopher [D-CT] (D-CT), 2025-09-17T00:00:00.000Z - Sen. Murray, Patty [D-WA] (D-WA), 2025-09-17T00:00:00.000Z - Sen. Reed, Jack [D-RI] (D-RI), 2025-09-17T00:00:00.000Z - Sen. Schatz, Brian [D-HI] (D-HI), 2025-09-17T00:00:00.000Z - Sen. Van Hollen, Chris [D-MD] (D-MD), 2025-09-17T00:00:00.000Z - Sen. Schiff, Adam B. [D-CA] (D-CA), 2025-09-30T00:00:00.000Z - Sen. Coons, Christopher A. [D-DE] (D-DE), 2026-08-06T00:00:00.000Z - Sen. Padilla, Alex [D-CA] (D-CA), 2026-09-14T00:00:00.000Z ## Provisions PRIA read - Annual tax on tradable investments: cost, high. If enacted, applicable taxpayers would have to treat tradable covered assets as if sold at fair market value each year and pay tax on gains. If you have a net marked‑to‑market loss, you could elect to carry it back up to three prior years, but carrybacks are limited. In your first year as an applic… - Higher tax and reporting on big deferred pay: cost, high. If enacted, applicable taxpayers would face a deferral recapture tax on deferred compensation and an extra 10% tax on severance pay included in income. The recapture uses past top rates, adds interest at the section 6621(b) rate plus 1 point, and is capped at 10% per item of compensation. Payers wh… - Net Investment Income Tax without AGI limit: cost, high. If enacted, applicable taxpayers would be subject to the Net Investment Income Tax (NIIT) without using the usual adjusted gross income threshold. That means applicable taxpayers could owe NIIT on investment income even when AGI would normally shield them. This change would apply for taxable years… - Tax on gifts, trusts, and transfers: cost, high. If enacted, many transfers by applicable taxpayers — including gifts, bequests, and transfers in trust — could be treated as sales at fair market value for tax purposes. Gifts and trust transfers generally would not show losses and transferee basis is usually set to the value at transfer. For trans… - Taxes and reporting for private life contracts: cost, high. If enacted, distributions from private placement life insurance or annuity contracts held by applicable taxpayers would be taxed under special rules and could face a 10% extra tax. Death benefits from those contracts would no longer be excluded from income for applicable taxpayers. Issuers and rein… - Who becomes an applicable taxpayer: cost, high. If enacted, you would be an "applicable taxpayer" only if in each of the past three taxable years you met either an income or asset test. The income test is adjusted gross income over $100 million ($50 million if married filing separately). The asset test is covered assets over $1 billion ($500 mil… - Limits on Opportunity Funds and small-business stock: cost, medium. If enacted, taxpayers who are (or ever were) applicable taxpayers could be barred from making Qualified Opportunity Fund elections for sales after September 17, 2025. The usual 10‑year basis step‑up for Opportunity Funds would be limited so your basis is the lesser of two fair market values, reduci… - Tighter rules for covered expatriates: cost, medium. If enacted, a covered expatriate who is an applicable taxpayer could not make the normal post‑expatriation sale election. The person would be treated as if they sold certain property at the end of the 10‑year expatriation period and would be taxable for each year in that 10‑year period. This change… ## Related bills - 119-s-2823: FAMILY Act - 119-s-51: Washington, D.C. Admission Act - 119-s-5108: Right to IVF Act of 2026 - 119-s-1503: Equality Act - 119-s-852: Richard L. Trumka Protecting the Right to Organize Act of 2025 - 119-s-2150: Women’s Health Protection Act of 2025 ## Sources - [119-s-2845 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/2845) ## Related - [119-s-2823: FAMILY Act](https://policyrisk.com/legislation/119-s-2823) - [119-s-51: Washington, D.C. Admission Act](https://policyrisk.com/legislation/119-s-51) - [119-s-5108: Right to IVF Act of 2026](https://policyrisk.com/legislation/119-s-5108) - [119-s-1503: Equality Act](https://policyrisk.com/legislation/119-s-1503) - [119-s-852: Richard L. Trumka Protecting the Right to Organize Act of 2025](https://policyrisk.com/legislation/119-s-852) - [119-s-2150: Women’s Health Protection Act of 2025](https://policyrisk.com/legislation/119-s-2150) - [All bills in Congress](https://policyrisk.com/legislation) Source: PRIA, https://policyrisk.com/legislation/119-s-2845 (as of 2026-10-08).