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119-s-788119th CongressWALLET

HOPE (Humans over Private Equity) for Homeownership Act

Sponsored By: Senator Merkley, Jeff [D-OR]

Introduced

Summary

Excise taxes and ownership limits on investor-held single-family homes. This bill would target large pooled investors by taxing purchases of 1–4 unit homes, charging annual fees for holding too many, and blocking key tax breaks for liable owners.

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  • Hedge funds and large pooled investors would pay a purchase tax on any newly acquired single-family residence equal to the greater of 15% of the purchase price or $10,000. A "hedge fund taxpayer" is defined to include pooled investors with at least $50 million in net value or assets under management.
  • Applicable pooled-entity owners would face a yearly excise of $5,000 for each single-family residence they hold above a changing maximum. The bill phases down permitted holdings over a roughly nine-year schedule that ends at 0% for hedge funds and at 50% for other applicable entities.
  • Owners subject to these excise rules would no longer be able to deduct mortgage interest or take depreciation for those single-family residences in taxable years after enactment.

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Bill Overview

Analyzed Economic Effects

4 provisions identified: 0 benefits, 4 costs, 0 mixed.

Annual $5,000 tax on excess homes

This bill would impose an annual excise of $5,000 for each single-family home an applicable taxpayer owns above a yearly cap. The cap is based on a baseline count and phases down each year (for hedge funds: 90% in year 1, 80% in year 2, down to 0% after year 9). A home sold in a "disqualified sale" during the year can still count as owned for that year.

Higher buy tax for hedge funds

This bill would require hedge fund taxpayers who buy a single-family home after enactment to pay a one-time tax equal to the larger of 15% of the home's purchase price (its adjusted basis) or $10,000. "Hedge fund taxpayer" means an applicable taxpayer meeting the bill's $50 million asset or net value test for the year.

Investors lose mortgage interest and depreciation

This bill would disallow two tax deductions for any owner liable under Chapter 50B for a taxable year. Covered owners could not deduct mortgage interest on acquisition loans for affected single-family homes. They also could not claim depreciation under section 167 for those homes for that taxable year.

Which investors and homes are covered

This bill would define who the rules apply to and what counts as a covered home. "Applicable taxpayer" covers entities that manage pooled investor funds and act as fiduciaries, with exclusions for 501(c)(3) charities and builders that sell newly built homes. A "hedge fund taxpayer" is any applicable taxpayer with $50,000,000 or more in net value or assets under management on any day in the taxable year. Single-family residence generally means 1–4 unit homes, and related entities are aggregated to prevent splitting ownership.

Sponsors & CoSponsors

Sponsor

Merkley, Jeff [D-OR]

OR • D

Cosponsors

  • Sen. King, Angus S., Jr. [I-ME]

    ME • I

    Sponsored 2/27/2025

  • Sen. Van Hollen, Chris [D-MD]

    MD • D

    Sponsored 2/27/2025

  • Sen. Gallego, Ruben [D-AZ]

    AZ • D

    Sponsored 2/27/2025

  • Sen. Sanders, Bernard [I-VT]

    VT • I

    Sponsored 2/27/2025

  • Sen. Kelly, Mark [D-AZ]

    AZ • D

    Sponsored 2/27/2025

  • Sen. Heinrich, Martin [D-NM]

    NM • D

    Sponsored 2/5/2026

Roll Call Votes

No roll call votes available for this bill.

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