HOPE (Humans over Private Equity) for Homeownership Act
Sponsored By: Senator Merkley, Jeff [D-OR]
Introduced
Summary
Targeted tax on hedge-fund purchases of single-family homes. This bill would impose a 15% excise tax on the purchase price of newly acquired single-family residences bought by large hedge-fund taxpayers and would tighten tax preferences and corporate tax treatment for those owners.
Show full summary
- Hedge-fund taxpayers: Large pooled-investment entities that manage $50 million or more would face a 15% excise tax on purchases of 1–4 unit residential properties. Properties used as a principal residence by someone with an ownership interest in the hedge fund are excluded.
- Tax deductions and depreciation: Mortgage interest and depreciation deductions for hedge-fund-owned single-family residences would be disallowed for taxable years after Dec. 31, 2030. Changes to qualified business income rules affecting hedge-fund trades phase in by 2035.
- Corporate surtax and aggregation: Certain corporations tied to hedge-fund activity would see the corporate tax rate rise by 5 percentage points for taxable years beginning after Dec. 31, 2035. The bill also applies aggregation rules to group related entities.
*If enacted, the bill would raise federal revenue by adding a 15% purchase excise tax and a higher corporate surtax on covered entities.*
Personalized for You
How does this bill affect your finances?
Personalize government policy and PRIA will tell you what this bill means for your household, plus every other piece of legislation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.
Bill Overview
Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
Hedge funds lose rental tax breaks
If enacted, the bill would stop certain tax breaks for hedge fund owners of 1-to-4 unit rental homes. Mortgage interest on acquisition debt for those single-family residences would not be deductible for covered hedge fund taxpayers starting for tax years after December 31, 2030. Depreciation deductions for those residences would also be disallowed after that date. The bill would also add hedge-fund trades or businesses to rules affecting the qualified business income deduction, with that change effective for tax years after December 31, 2035.
15% purchase tax on hedge fund homes
If enacted, the bill would impose a one-time excise tax equal to 15 percent of the purchase price when a covered hedge fund taxpayer acquires a 1-to-4 unit residential property. The purchase price is the property's adjusted basis on the purchase date, and acquisition includes getting a majority ownership interest. The tax would not apply if, immediately after purchase and at all times after, the property is not rented and is used as the principal home of a person who has an ownership interest in the acquiring hedge fund taxpayer. The excise tax rule would apply to properties bought in tax years beginning after enactment.
Who counts as a hedge fund taxpayer
If enacted, the bill would define a "hedge fund taxpayer" as an applicable entity that manages pooled investor funds, acts as a fiduciary, and has $50,000,000 or more in net value or assets under management on any day in the taxable year. Applicable entities include partnerships, corporations, and REITs but exclude 501(c)(3) organizations and businesses mainly building single-family homes to sell. The bill would also apply aggregation rules so related entities are treated as one person for this test. These rules would take effect for tax years beginning after enactment.
Higher corporate tax for hedge funds
If enacted, the bill would raise the corporate income tax rate by 5 percentage points for corporations that qualify as hedge fund taxpayers under the bill. That change would apply to taxable years beginning after December 31, 2035. The increase targets corporate entities that meet the hedge fund definition in the bill.
Sponsors & CoSponsors
Sponsor
Merkley, Jeff [D-OR]
OR • D
Cosponsors
Sen. Hawley, Josh [R-MO]
MO • R
Sponsored 2/26/2026
Roll Call Votes
No roll call votes available for this bill.
View on Congress.gov