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S 2845119th CongressIn Committee
Billionaires Income Tax Act
Introduced: Sep 17, 2025
Sponsor: Sen. Wyden, Ron [D-OR] (D-Oregon)
Economy & Taxes
Standard Summary
Comprehensive overview in 1-2 paragraphs
This bill aims to close tax loopholes that allow billionaires to avoid paying taxes by using the "buy, borrow, die" strategy—where wealthy individuals purchase assets, borrow against their increasing value tax-free, and pass them to heirs who receive a stepped-up tax basis that eliminates capital gains taxes. The legislation would modify more than 30 provisions in the Internal Revenue Code to require billionaires to pay taxes on their wealth annually rather than deferring taxation indefinitely. This represents a significant shift in how the wealthiest Americans are taxed, moving from a realization-based system (where taxes are paid only when assets are sold) to a system requiring annual tax payments on wealth accumulation.
Key Points
- 1Targets the "buy, borrow, die" loophole where billionaires avoid capital gains taxes by holding appreciating assets, borrowing against them, and passing them to heirs with a stepped-up basis
- 2Requires annual tax payments from billionaires rather than allowing indefinite tax deferral on unrealized gains
- 3Modifies over 30 tax code provisions specifically affecting how the wealthiest individuals are taxed
- 4Focuses exclusively on billionaires, creating a distinct tax treatment for the ultra-wealthy class
- 5Aims to increase tax revenue by ensuring the wealthiest Americans pay taxes more consistently throughout their lifetimes
Impact Areas
Billionaires and ultra-high-net-worth individuals who would face new annual tax obligations on their wealthFederal tax revenue which would likely increase substantially from closing these loopholesEstate planning and wealth management industries that would need to adapt strategies for ultra-wealthy clientsIncome inequality debates as the bill addresses concerns about wealth concentration and tax fairness
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