# 119-s-4279: PPLI Abuse Act

119-s-4279, PPLI Abuse 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 2026-04-22).

- Canonical: https://policyrisk.com/legislation/119-s-4279
- As of: 2026-04-22
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-4279
- Congress: 119
- Title: PPLI Abuse Act
- Status: introduced
- Introduced: 2026-04-13
- Sponsor: Sen. Wyden, Ron [D-OR] (D-OR)
- Cosponsors: 0
- Policy area: unknown
- Touches household money: yes
- Last recorded action: 2026-04-22

## Summary

**Would create a new federal tax and reporting regime for certain private placement life and annuity contracts.** It defines "Applicable Private Placement Contracts" and changes how holders, issuers, and foreign reporting rules would treat those contracts for tax and compliance purposes. - Holders of these contracts would be treated as owning a share of the segregated asset account and must include their share of net income or net loss. Excess distributions would be ordinary income and the holder's basis would adjust for premiums, includible income, and allowable losses. - Issuers would have to back each contract by proportionate assets in segregated accounts that support at least 25 contracts. Premiums and reserves related to these contracts would not qualify as life-insurance premiums or reserves under existing life-insurance tax rules. - Issuers and reinsurers would face new reporting and disclosure duties, including an initial return due within 30 days after the later of 180 days post-enactment or the date a contract becomes an APPC, and annual returns. Failures could trigger a $1 million base penalty plus $1 million for each 30-day penalty period. The bill would also fold these contracts and segregated accounts into Foreign Account Tax Compliance Act rules, affecting foreign reporting and certain payments one year after enactment.

## Provisions PRIA read

- APPC holders taxed like owners: cost, high. If enacted, the bill would stop treating APPCs as tax-preferred life insurance or annuity contracts. Holders would be treated as if they owned a pro rata share of the segregated account assets and would include their share of net income or net loss for tax. Payouts above your applicable adjusted ba…
- APPCs treated as FATCA financial accounts: cost, medium. The bill would amend FATCA to count certain APPCs and their segregated asset accounts as "financial accounts." It would also add a life-insurance entity classification for FATCA and narrow an exception so fewer payments are excluded. Those FATCA changes would apply to payments made one year after e…
- Segregated accounts must back 25 contracts: cost, medium. The bill would require segregated asset accounts that back APPCs to support at least 25 private placement contracts. Each contract in the account would have to be supported only by assets in that account and each asset must back contracts in the same proportion. All private placement contracts held…
- New APPC reporting and big penalties: mixed, high. The bill would require issuers and reinsurers to file an initial APPC return by the "applicable date" (30 days after the later of 180 days after enactment or the date the contract became an APPC). Issuers would file annual returns and must send payee statements by January 31 with income, losses, di…
- Which private contracts become APPCs: mixed, medium. This bill would define which variable life or annuity contracts count as an "applicable private placement contract" (APPC). It would treat contracts sold under private placement suitability rules as APPCs and would name issuers and reinsurers as "reporting issuers." Most APPC tax rules would take e…

## Related bills

- 119-s-891: Bipartisan Health Care Act
- 119-s-5071: Children's Safe Welcome Act of 2026
- 119-s-5022: Cannabis Administration and Opportunity Act
- 119-s-2819: Head Start for America's Children Act
- 119-s-4504: Full-Service Community School Expansion Act of 2026
- 119-s-3990: PrEP Access and Coverage Act of 2026

## Sources
- [119-s-4279 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/4279)

## Related
- [119-s-891: Bipartisan Health Care Act](https://policyrisk.com/legislation/119-s-891)
- [119-s-5071: Children's Safe Welcome Act of 2026](https://policyrisk.com/legislation/119-s-5071)
- [119-s-5022: Cannabis Administration and Opportunity Act](https://policyrisk.com/legislation/119-s-5022)
- [119-s-2819: Head Start for America's Children Act](https://policyrisk.com/legislation/119-s-2819)
- [119-s-4504: Full-Service Community School Expansion Act of 2026](https://policyrisk.com/legislation/119-s-4504)
- [119-s-3990: PrEP Access and Coverage Act of 2026](https://policyrisk.com/legislation/119-s-3990)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-4279 (as of 2026-04-22).