# 119-s-4330: Ending the Carried Interest Loophole Act

119-s-4330, Ending the Carried Interest Loophole 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 2026-08-01).

- Canonical: https://policyrisk.com/legislation/119-s-4330
- As of: 2026-08-01
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-4330
- Congress: 119
- Title: Ending the Carried Interest Loophole Act
- Status: introduced
- Introduced: 2026-04-16
- Sponsor: Sen. Wyden, Ron [D-OR] (D-OR)
- Cosponsors: 14
- Policy area: Environmental Protection
- Touches household money: yes
- Last recorded action: 2026-08-01

## Summary

**Taxes many service-related partnership interests at their full liquidation value.** This bill would rewrite Section 83(c) so that when someone gets a partnership interest for performing services its value is the cash the partnership would pay in a complete taxable liquidation, and recipients are treated as having made an 83(b) election unless they opt out. - Fund managers and service partners: Recipients would generally recognize income equal to their share of the partnership's liquidation value when they receive the interest. They are treated as having made an 83(b) election unless they elect out. - Partnerships and investors: The recognized amount is added to the recipient's capital account for Subchapter K. For interests that qualify under Section 1299, the amount is treated as the recipient's invested capital, and the bill repeals Section 1061 and creates a new Part VII in Subchapter P to house the rule. - Loans and financial instruments: The bill defines "applicable loans" and creates a safe harbor for loans that are fully recourse or fully secured and that require interest at a specified rate. It also lets certain financial instruments and interests in non-partnership entities be treated as partnership interests for these rules.

## Cosponsors (14)

- Sen. Whitehouse, Sheldon [D-RI] (D-RI), 2026-04-16T00:00:00.000Z
- Sen. King, Angus S., Jr. [I-ME] (I-ME), 2026-04-16T00:00:00.000Z
- Sen. Warren, Elizabeth [D-MA] (D-MA), 2026-04-16T00:00:00.000Z
- Sen. Sanders, Bernard [I-VT] (I-VT), 2026-04-16T00:00:00.000Z
- Sen. Smith, Tina [D-MN] (D-MN), 2026-04-16T00:00:00.000Z
- Sen. Luján, Ben Ray [D-NM] (D-NM), 2026-04-16T00:00:00.000Z
- Sen. Schatz, Brian [D-HI] (D-HI), 2026-04-16T00:00:00.000Z
- Sen. Reed, Jack [D-RI] (D-RI), 2026-04-16T00:00:00.000Z
- Sen. Hirono, Mazie K. [D-HI] (D-HI), 2026-04-16T00:00:00.000Z
- Sen. Markey, Edward J. [D-MA] (D-MA), 2026-04-16T00:00:00.000Z
- Sen. Fetterman, John [D-PA] (D-PA), 2026-04-16T00:00:00.000Z
- Sen. Blumenthal, Richard [D-CT] (D-CT), 2026-04-16T00:00:00.000Z
- Sen. Van Hollen, Chris [D-MD] (D-MD), 2026-04-16T00:00:00.000Z
- Sen. Gallego, Ruben [D-AZ] (D-AZ), 2026-07-30T00:00:00.000Z

## Provisions PRIA read

- Annual tax on carried interest: cost, high. If enacted, holders of certain partnership interests would have to include a yearly "deemed compensation amount" as ordinary income. The amount equals the specified rate (the first segment rate for the first month plus 9 percentage points) times any excess of a partnership-wide invested-capital mea…
- New valuation for service partnership interests: cost, medium. If enacted, the bill would treat the value of a partnership interest you receive for services as the cash you would get if the partnership sold all assets at fair market value, paid liabilities, and liquidated. You would be treated as having made the Section 83(b) election unless you timely elect n…
- Repeal of carried interest rule: mixed, high. If enacted, this bill would repeal Section 1061, the current special rule that treats some partnership gains as long-term capital gains. That repeal would change how certain investment managers and service partners pay tax on partnership gains and could raise taxes for some taxpayers. The repeal wo…

## Related bills

- 119-s-5066: Health Equity and Accountability Act of 2026
- 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
- 119-s-2523: John R. Lewis Voting Rights Advancement Act of 2025

## Sources
- [119-s-4330 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/4330)

## Related
- [119-s-5066: Health Equity and Accountability Act of 2026](https://policyrisk.com/legislation/119-s-5066)
- [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)
- [119-s-2523: John R. Lewis Voting Rights Advancement Act of 2025](https://policyrisk.com/legislation/119-s-2523)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-4330 (as of 2026-08-01).