# 119-s-445: Carried Interest Fairness Act of 2025

119-s-445, Carried Interest Fairness Act of 2025, is a 119th Congress bill sponsored by Sen. Baldwin, Tammy [D-WI] (D-WI); status introduced; PRIA reads it as touching household money (as of 2026-10-21).

- Canonical: https://policyrisk.com/legislation/119-s-445
- As of: 2026-10-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-445
- Congress: 119
- Title: Carried Interest Fairness Act of 2025
- Status: introduced
- Introduced: 2025-02-06
- Sponsor: Sen. Baldwin, Tammy [D-WI] (D-WI)
- Cosponsors: 14
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-10-21

## Summary

**Would reclassify carried interest and other investment-manager returns as ordinary income instead of capital gains.** It would also change how partnership interests received for services are valued and impose new reporting, penalty, and Social Security rules. - Investment managers and partners would see net capital gains from an "investment services partnership interest" treated as ordinary income and net capital losses treated as ordinary losses subject to a limitation. It would also make the fair market value of service-linked partnership interests equal to the liquidation-value distribution and treat recipients as having made a Section 83(b) election unless they opt out. - Partnerships and investors would lose the ability to count certain carried-interest income as qualifying income for publicly traded partnership status under Section 7704. A transitional rule delays that nonqualifying treatment for up to 10 years for affected partnership taxable years. - Tax administration and workers would face stricter rules and enforcement. The bill would raise the accuracy-related penalty to 40% for underpayments tied to avoidance of these rules, expand reporting and valuation requirements, grant Treasury anti-abuse authority, and include investment-services partnership income in net earnings from self-employment for Social Security purposes.

## Cosponsors (14)

- Sen. Van Hollen, Chris [D-MD] (D-MD), 2025-02-06T00:00:00.000Z
- Sen. Murray, Patty [D-WA] (D-WA), 2025-02-06T00:00:00.000Z
- Sen. Schatz, Brian [D-HI] (D-HI), 2025-02-06T00:00:00.000Z
- Sen. Markey, Edward J. [D-MA] (D-MA), 2025-02-06T00:00:00.000Z
- Sen. Klobuchar, Amy [D-MN] (D-MN), 2025-02-06T00:00:00.000Z
- Sen. Kaine, Tim [D-VA] (D-VA), 2025-02-06T00:00:00.000Z
- Sen. Merkley, Jeff [D-OR] (D-OR), 2025-02-06T00:00:00.000Z
- Sen. Reed, Jack [D-RI] (D-RI), 2025-02-06T00:00:00.000Z
- Sen. Hirono, Mazie K. [D-HI] (D-HI), 2025-02-06T00:00:00.000Z
- Sen. Warren, Elizabeth [D-MA] (D-MA), 2025-02-06T00:00:00.000Z
- Sen. Sanders, Bernard [I-VT] (I-VT), 2025-02-06T00:00:00.000Z
- Sen. Booker, Cory A. [D-NJ] (D-NJ), 2025-02-06T00:00:00.000Z
- Sen. Welch, Peter [D-VT] (D-VT), 2025-02-06T00:00:00.000Z
- Sen. Luján, Ben Ray [D-NM] (D-NM), 2025-04-01T00:00:00.000Z

## Provisions PRIA read

- Carried interest taxed as ordinary income: cost, high. If enacted, the bill would make many carried-interest allocations and related partnership gains ordinary income instead of capital gain. The rule applies only to defined investment-services partnership interests and does not apply to the portion that is a bona fide capital contribution. Dividends o…
- Higher taxes and reporting for fund managers: cost, high. If enacted, the bill would count investment-services partnership income as self-employment earnings, raising self-employment tax and affecting Social Security credits. Recipients of partnership interests for services would be valued using a liquidation rule and treated as having made an 83(b)-type…

## Related bills

- 119-s-5066: Health Equity and Accountability Act of 2026
- 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-445 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/445)

## Related
- [119-s-5066: Health Equity and Accountability Act of 2026](https://policyrisk.com/legislation/119-s-5066)
- [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-445 (as of 2026-10-21).