ROBINHOOD Act of 2026
Sponsored By: Senator Gallego, Ruben [D-AZ]
Introduced
Summary
Treats certain loans by very wealthy taxpayers as immediate taxable sales of long-term assets. It would use multi-year income and asset look-backs to force gain recognition when targeted taxpayers take out loans or enter long leases.
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Bill Overview
Analyzed Economic Effects
3 provisions identified: 0 benefits, 2 costs, 1 mixed.
Loans and long leases trigger taxes
If enacted, loans to an applicable taxpayer would be treated as forcing a sale of long-term capital assets. You would have to identify long-term assets with gain up to the loan principal and treat them as sold at fair market value on the last day of the loan year, and you would recognize the gain in that year. That deemed gain could not be reduced by long-term capital losses that year. Loans to pass-through entities would be allocated pro rata to owners, and owners must be notified within 30 days. Leases with initial terms over five years would be treated like loans for these rules.
Who counts as a very wealthy taxpayer
This bill would set very high income and asset tests to decide who is covered. You would be an "applicable taxpayer" if, for each of the three prior years, your modified AGI was over $100 million (or $50 million if married filing separately) or your covered assets were over $1 billion (or $500 million MFS). The bill would also make a non-grantor trust an "applicable trust" if, for each of the three prior years, the trust's income was over $10 million or its assets were over $100 million, while listing several excluded trust types. The bill would tell taxpayers how to value covered assets (tradable assets at fair market value; nontradable assets by the highest of several measures) and would apply to tax years beginning after December 31, 2026.
Marriage, divorce, and termination rules
The bill would treat a person who becomes married as making both spouses subject to the rules for the marriage year and later years. If a married person filing separately is treated as applicable, the spouse would also be treated as applicable that year. You could stop being treated as an applicable taxpayer only after a three-year look-back using half-sized thresholds and by making an election. A divorced taxpayer could elect earlier termination if, in the first year after divorce, their income is under $1,000,000 or assets are under $10,000,000.
Sponsors & CoSponsors
Sponsor
Gallego, Ruben [D-AZ]
AZ • D
Cosponsors
There are no cosponsors for this bill.
Roll Call Votes
No roll call votes available for this bill.
View on Congress.gov