,i #aahth ,,congress #b;d ,session ,h4 ,r4 #ggdi ,,in ,,the ,,house ,,of ,,representatives ,march #bj1 #bjbd,ms4 ,jayapal 7for herself1 ,mr4 ,boyle of ,pennsylvania1 ,mr4 ,beyer1 ,mr4 ,bowman1 ,ms4 ,bush1 ,ms4 ,chu1 ,mr4 ,davis of ,illinois1 ,mr4 ,evans1 ,mr4 ,garca of ,illinois1 ,mr4 ,goldman of ,new ,york1 ,mr4 ,grijalva1 ,mr4 ,ivey1 ,mr4 ,jackson of ,illinois1 ,mr4 ,johnson of ,georgia1 ,ms4 ,lee of ,california1 ,ms4 ,lee of ,pennsylvania1 ,mr4 ,mc,govern1 ,mr4 ,nadler1 ,ms4 ,norton1 ,ms4 ,ocasio-,cortez1 ,ms4 ,omar1 ,ms4 ,porter1 ,ms4 ,pressley1 ,mrs4 ,ramirez1 ,ms4 ,schakowsky1 ,mr4 ,schiff1 ,mr4 ,smith of ,washington1 ,mr4 ,takano1 ,ms4 ,tlaib1 ,ms4 ,tokuda1 ,mr4 ,trone1 ,ms4 ,waters1 ,mrs4 ,watson ,coleman1 and ,ms4 ,wild7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to impose a tax on the net value of assets of a taxpayer1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,ultra-,millionaire ,tax ,act of #bjbd4 #b4 ,imposition of wealth tax 7a7 ,in general ,the ,internal ,revenue ,code of #aihf is amended by inserting after subtitle ,b the following new subtitle3 ,b-#a ,wealth tax ,chapter #ah--;,determination of wealth tax #ah ,determination of wealth tax ,sec4 #bija4 ,imposition of tax4 ,sec4 #bijb4 ,net value of taxable assets4 ,sec4 #bijc4 ,special rules4 ,sec4 #bijd4 ,information reporting4 ,sec4 #bije4 ,enforcement4 #bija4 ,imposition of tax 7a7 ,in general ,in the case of an individual1 a tax is hereby imposed on the net value of all taxable assets of the taxpayer on the last day of any calendar year4 7b7 ,computation of tax 7#a7 ,in general ,the tax imposed by this section shall be equal to the sum of-- 7,a7 #j percent of so much of the net value of all taxable assets of the taxpayer as does not exceed the zero bracket threshold1 7,b7 #b percent of so much of the net value of all taxable assets of the taxpayer in excess of the zero bracket threshold but not in excess of the top bracket threshold1 plus 7,c7 the applicable percentage of so much of the net value of all such taxable assets of the taxpayer in excess of the top bracket threshold4 7#b7 ,zero bracket threshold2 top bracket threshold ,for purposes of this section-- 7,a7 ,zero bracket threshold ,the zero bracket threshold is #ej1jjj1jjj4 7,b7 ,top bracket threshold ,the top bracket threshold is #a1jjj1jjj1jjj4 7c7 ,applicable percentage 7#a7 ,in general ,for purposes of this section1 the applicable percentage is-- 7,a7 except as provided in subparagraph 7,b71 #c percent1 and 7,b7 in the case of any calendar year in which there is in effect legislation which meets the requirements of paragraph 7#b71 #f percent4 7#b7 ,legislation described ,legislation meets the requirements of this paragraph if such legislation-- 7,a7 establishes a health insurance program that provides to all residents of the ,united ,states comprehensive protection against the costs of health care and health-related services1 and 7,b7 prohibits private entities from providing duplicate benefits4 7d7 ,treatment of married individuals ,for purposes of this section1 individuals who are married 7as defined in section #ggjc7 shall be treated as one taxpayer4 7e7 ,treatment of nongrantor multibeneficiary trusts 7#a7 ,in general ,any trust or portion of a trust which is a nongrantor multibeneficiary trust shall be treated as an individual to whom this chapter applies4 7#b7 ,computation of tax 7,a7 ,in general ,in applying this chapter to a nongrantor multibeneficiary trust-- 7i7 the zero bracket threshold shall be equal to the sum of-- 7,i7 #j1 plus 7,,ii7 the lowest unused #j percent bracket amount assigned to the trust by all beneficiaries of the trust1 and 7ii7 the top bracket threshold shall be equal to the sum of-- 7,i7 #j1 plus 7,,ii7 the lowest unused #b percent bracket amount assigned to the trust by all beneficiaries of the trust4 7,b7 ,unused #j percent bracket amount ,for purposes of this paragraph1 the term unused #j percent bracket amount means1 with respect to any beneficiary for any calendar year1 the lesser of-- 7i7 the excess 7if any7 of-- 7,i7 the zero bracket threshold1 over 7,,ii7 the sum of-- 7aa7 the net value of all taxable assets of the beneficiary for the calendar year1 plus 7bb7 any unused #j percent bracket amount assigned by the beneficiary to other nongrantor multibeneficiary trusts1 or 7ii7 the portion of the net value of all taxable assets of the trust which such beneficiary is eligible to receive4 7,c7 ,unused #b percent bracket amount ,for purposes of this paragraph1 the term unused #b percent bracket amount means1 with respect to any beneficiary for any calendar year1 the lesser of-- 7i7 the excess 7if any7 of-- 7,i7 the top bracket threshold reduced by the zero bracket threshold1 over 7,,ii7 the sum of-- 7aa7 the net value of all taxable assets of the beneficiary for the calendar year in excess of the zero bracket threshold1 plus 7bb7 any unused #b percent bracket amount assigned by the beneficiary to other nongrantor multibeneficiary trusts1 or 7ii7 the portion of the net value of all taxable assets of the trust which such beneficiary is eligible to receive4 7,d7 ,assignment of amounts ,the assignment of any amount of unused #j percent bracket amount and unused #b percent bracket amount shall be made at such time and in such manner as specified by the ,secretary in regulations4 ,in any case in which no affirmative assignment is made by a beneficiary1 the amount assigned shall be #j4 7#c7 ,nongrantor multibeneficiary trust ,for purposes of this chapter-- 7,a7 ,in general ,the term nongrantor multibeneficiary trust means any trust or portion of a trust-- 7i7 with respect to which no person is treated as an owner under subpart ,e of subchapter ,j of chapter #a1 7ii7 no property of which is attributable to a gratuitous transfer of assets by a person who is subject to tax under this chapter for the calendar year1 and 7iii7 which has more than one beneficiary 7determined as of the last day of the calendar year74 7,b7 ,exception ,such term shall not include-- 7i7 any trust described in section #dja7;a7 and exempt from tax under section #eja7;a71 7ii7 any trust all of the unexpired interests in which are devoted to one or more of the purposes described in section #agj7;c77#b77;,b71 7iii7 any charitable lead annuity trust 7as defined in section #bfdb7;e77#c77 or charitable lead unitrust1 or 7iv7 any charitable annuity remainder trust 7as defined in section #ffd7;d77#a77 or any charitable remainder unitrust 7as defined in section #ffd7;d77#b774 7,c7 ,beneficiary ,the term beneficiary shall not include any person whose interest in a trust is contingent on the death of another person with an interest in such trust4 #bijb4 ,net value of taxable assets 7a7 ,in general ,for purposes of this subtitle1 the term net value of all taxable assets means1 as of any date1 the value of all property of the taxpayer 7other than property excluded under subsection 7b771 real or personal1 tangible or intangible1 wherever situated1 reduced by any debts 7including any debts secured by property excluded under subsection 7b77 owed by the taxpayer4 7b7 ,exclusion for certain assets ,property of the taxpayer shall not be taken into account under subsection 7a7 if such property-- 7#a7 has a value of #ej1jjj or less 7determined without regard to any debt owed by the taxpayer with respect to such property71 7#b7 is tangible personal property1 and 7#c7 is not property-- 7,a7 which is used in a trade or business of the taxpayer1 7,b7 in connection with which a deduction is allowable under section #bab1 or 7,c7 which is a collectible as defined in section #djh7m71 a boat1 an aircraft1 a mobile home1 a trailer1 a vehicle1 or an antique or other asset that maintains or increases its value over time 7within the meaning of section #e4jb7b7 of ,revenue ,procedure #bjah-jh74 7c7 ,rules for determining property of the taxpayer ,for purposes of this subtitle-- 7#a7 ,property included in estate ,any property that would be included in the estate of the taxpayer if the taxpayer died shall be treated as property of the taxpayer4 7#b7 ,inclusion of certain gifts ,any property transferred by the taxpayer after the date of the enactment of this chapter1 to an individual who is a member of the family of the taxpayer 7as determined under section #bfg7;c77#d77 and has not attained the age of #ah shall be treated as property of the taxpayer for any calendar year before the year in which such individual attains the age of #ah4 7#c7 ,attribution of property held by trusts 7,a7 ,grantor trusts ,if an individual is treated as the owner of any portion of a trust under subpart ,e of subchapter ,j of chapter #a1 property attributable to such trust or portion of the trust shall be treated as property of the individual and not as property of the trust4 7,b7 ,nongrantor trusts 7i7 ,in general ,in the case of a trust or portion of a trust which is not described in subparagraph 7,a71 any property which is attributable to a gratuitous transfer of assets by an individual who is subject to tax under this chapter for the calendar year shall be treated as property of such individual and not as property of the trust4 7ii7 ,other trusts 7,i7 ,in general ,in the case of any trust or portion of a trust which is described in subclause 7,,ii71 the property of such trust shall be treated as the property of the beneficiary of such trust and not as the property of the trust4 7,,ii7 ,trusts to which this subclause applies ,a trust is described in this subclause if such trust not described in subparagraph 7,a71 the assets of such trust are not attributable to a gratuitous transfer of assets by a person who is subject to tax under this chapter for the calendar year1 and such trust has a single beneficiary 7determined as of the last day of the calendar year74 7,c7 ,right of recovery 7i7 ,in general ,if any part of the net value of taxable assets of an individual on which tax has been paid consists of the value of property held by a trust which is included in the net value of taxable assets of such individual by reason of subparagraph 7,b71 then such individual shall be entitled to recover from the trust the amount which bears the same ratio to the recoverable amount as-- 7,i7 the value of such property1 bears to 7,,ii7 the net value of taxable assets of the taxpayer4 7ii7 ,recoverable amount ,for purposes of clause 7i71 the recoverable amount with respect to any trust is the excess of-- 7,i7 the tax imposed under this chapter for the calendar year on the individual1 over 7,,ii7 the amount of such tax which would be imposed for such calendar year on such individual if no property held by such trust were included in the net value of taxable assets of the individual4 7iii7 ,treatment where no recovery ,in any case where a trust does not reimburse any taxpayer as provided in clause 7i71 the taxpayer shall be treated for purposes of this chapter as having made a gratuitous transfer to the trust in an amount equal to the amount determined under clause 7i74 ,such transfer shall be treated as having been made on the last day of the calendar year for which the tax under subsection 7a7 was due4 7#d7 ,treatment of assets held by certain split-interest trusts 7,a7 ,remainder interests in charitable remainder annuity trusts and charitable remainder unitrusts ,in the case of any charitable remainder annuity trust 7as defined in section #ffd7;d77#a77 or of a charitable remainder unitrust 7as defined in section #ffd7;d77#b77-- 7i7 the present value of any remainder interest shall not be taken into account under subsection 7a71 and 7ii7 the present value of any other interests shall be taken in account under subsection 7a71 in accordance with regulations promulgated by the ,secretary1 as the property of the beneficiaries of such interests4 7,b7 ,charitable lead annuity trusts and charitable lead unitrusts ,in the case of a charitable lead annuity trust 7as defined in section #bfdb7;e77#c77 or a charitable lead unitrust-- 7i7 the present value of any interest described in section #bebb7;c77#b77;,b7 shall not be taken into account under subsection 7a71 and 7ii7 notwithstanding paragraphs 7,a7 and 7,b7 of paragraph 7#c71 the present value of any remainder interest shall be taken into account under subsection 7a71 in accordance with regulations promulgated by the ,secretary1 as the property of the beneficiaries of such remainder interest4 7d7 ,establishment of valuation rules ,not later than #ab months after the date of the enactment of this section1 the ,secretary shall establish rules and methods for determining the value of any asset for purposes of this subtitle1 including rules for the valuation of assets that are not publicly traded or that do not have a readily ascertainable value4 ,such rules and methods-- 7#a7 may utilize retrospective and prospective formulaic valuation methods not currently in use by the ,secretary1 7#b7 may require the use of formulaic valuation approaches for designated assets1 including formulaic approaches based on proxies for determining presumptive valuations1 formulaic approaches based on prospective adjustments from purchase prices or other prior events1 or formulaic approaches based on retrospectively adding deferral charges based on eventual sale prices or other specified later events indicative of valuation1 and 7#c7 may address the use of valuation discounts4 #bijc4 ,special rules 7a7 ,deceased individuals 7#a7 ,in general ,in the case of any individual who dies during a calendar year and who is not married on the date of such individual's death-- 7,a7 section #bija7;a7 shall be applied by substituting the date of the individual's death for the last day of the calendar year1 and 7,b7 the amount of the tax imposed under such section shall be reduced by an amount which bears the same ratio to such amount 7determined without regard to this subsection7 as-- 7i7 the number of days in the calendar year after the date of the individual's death1 bears to 7ii7 #cfe4 7#b7 ,coordination with estate tax ,for purposes of section #bjec1 the tax imposed by this section for the year of the decedent's death shall be considered to have been imposed before such death4 7b7 ,application to non-,residents ,in the case of any individual who is a non-resident and not a citizen of the ,united ,states1 this subtitle shall apply only to the property of such individual which is situated in the ,united ,states 7determined under rules similar to the rules under subchapter ,b of chapter #aa74 7c7 ,application to covered expatriates ,in the case of an individual who is a covered expatriate 7as defined in section #hgg;,a71 section #bija7;a7 shall be applied-- 7#a7 as if the calendar year ended on the day before the expatriation1 and 7#b7 as if the rate of tax under both subparagraphs 7,a7 and 7,b7 of section #bija7;b77#a7 were #dj percent4 #bijd4 ,information reporting 7a7 ,in general ,not later than #ab months after the date of the enactment of this section1 the ,secretary shall by regulations require the reporting of any information concerning the net value of assets appropriate to enforce the tax imposed by this chapter4 7b7 ,method of reporting ,the ,secretary shall1 where appropriate1 require the reporting made under subsection 7a7 to be made as a part of existing income reporting requirements 7including requirements under chapter #d 7relating to taxes to enforce reporting on certain foreign accounts774 7c7 ,responsibility for reporting ,the ,secretary may impose reporting obligations by reference to the ownership1 control1 management1 claim to income from1 or other relationship to assets and liabilities for purposes of administering the tax imposed by this section and may impose such obligations on financial institutions1 business entities1 or other persons1 including requiring business entities to provide estimates of the value of the entity itself4 #bije4 ,enforcement ,the ,secretary shall annually audit not less than #cj percent of taxpayers required to pay the tax imposed under this chapter4 4 7b7 ,no deduction from income taxes ,section #bge of the ,internal ,revenue ,code of #aihf is amended by inserting after paragraph 7#f7 the following new paragraph3 7#g7 ,taxes imposed by chapter #ah4 4 7c7 ,extension of time for payment of tax 7#a7 ,in general ,section #fafa7;a7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new paragraph3 7#c7 ,wealth tax 7,a7 ,in general ,in the case of taxpayer described in subparagraph 7,b71 the ,secretary may extend the time for payment of the tax imposed under chapter #ah for a reasonable period not to exceed #e years from the date fixed for the payment thereof4 7,b7 ,taxpayers described ,a taxpayer is described in this subparagraph if such the ,secretary determines-- 7i7 the taxpayer has severe liquidity constraints1 or 7ii7 immediate payment would cause undue hardship on an ongoing enterprise4 4 7#b7 ,rules ,not later than #ab months after the date of the enactment of this ,act1 the ,secretary of the ,treasury 7or the ,secretary's delegate7 shall establish rules for the application of the amendments made by paragraph 7#a74 7d7 ,application of accuracy related penalties 7#a7 ,in general ,section #fffb7;b7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new paragraph3 7#aj7 ,any substantial wealth tax valuation understatement4 4 7#b7 ,substantial wealth tax understatement ,section #fffb of such ,code is amended by adding at the end the following new subsection3 7m7 ,application to substantial wealth tax valuation understatement 7#a7 ,substantial wealth tax valuation understatement defined 7,a7 ,in general ,for purposes of this section1 there is a substantial wealth tax valuation understatement if the value of any property claimed on any return of tax imposed by subtitle ,b-#a is #fe percent or less of the amount determined to be the correct amount of such valuation4 7,b7 ,limitation ,no penalty shall be imposed by reason of subsection 7b77#aj7 unless the portion of the underpayment attributable to substantial wealth tax valuation understatements for the calendar year exceeds #e1jjj4 7#b7 ,increased penalty 7,a7 ,in general ,in the case of any portion of an underpayment which is attributable to one or more substantial wealth tax valuation understatement1 subsection 7a7 shall be applied-- 7i7 in the case of a substantial wealth tax valuation understatement which is a gross wealth tax valuation misstatement1 by substituting #ej percent for #bj percent1 and 7ii7 in any other case1 by substituting #cj percent for #bj percent4 7,b7 ,gross wealth tax valuation misstatement ,for purposes of subparagraph 7,a71 the term gross wealth tax valuation misstatement means a substantial wealth tax valuation understatement1 as determined under paragraph 7#a7 by substituting #dj percent for #fe percent4 4 7e7 ,clerical amendment ,the table of subtitles of such ,code is amended by inserting after the item relating to subtitle ,b the following new item3 ,subtitle ,b-#a--,wealth tax 4 7f7 ,effective date ,the amendments made by this section shall apply to calendar years beginning after ,december #ca1 #bjbd4 7g7 ,periodic reports ,not later than ,january #a1 #bjbg1 and every #b years thereafter1 the ,secretary of the ,treasury 7or the ,secretary's delegate7 shall submit to ,congress a report on the tax imposed under chapter #ah of the ,internal ,revenue ,code of #aihf 7as added by this ,act71 including any issues related to the administration and enforcement of such tax4 #c4 ,strengthening disclosure requirements 7a7 ,regulatory authority ,the ,secretary of the ,treasury 7or the ,secretary's delegate7 may issue such rules and regulations as necessary to prevent taxpayers from avoiding the purpose of information reporting requirements under the ,internal ,revenue ,code of #aihf by placing assets in any foreign corporation1 partnership1 or trust in which the taxpayer holds directly or indirectly1 a significant interest as the sole or principal owner or the sole or principal beneficial owner4 7b7 ,,fatca enforcement plan ,the ,secretary of the ,treasury 7or the ,secretary's delegate7 shall develop a comprehensive plan for managing efforts to leverage data collected under chapter #d of the ,internal ,revenue ,code of #aihf in agency compliance efforts4 ,such plan shall include an evaluation of the extent to which actions being undertaken as of the date of the enactment of this ,act for the enforcement of the requirements of such chapter improve voluntary compliance and address noncompliance with such requirements4 #d4 ,internal ,revenue ,service funding 7a7 ,in general ,subchapter ,a of chapter #hj of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #ghac4 ,authorization of appropriations ,there are authorized to be appropriated to the ,secretary for the period of fiscal years #bjbd through #bjcd-- 7#a7 for enforcement of this title1 #gj1jjj1jjj1jjj1 7#b7 for taxpayer services1 #aj1jjj1jjj1jjj1 and 7#c7 for business system modernization1 #bj1jjj1jjj1jjj4 4 7b7 ,clerical amendment ,the table of sections for subchapter ,a of chapter #hj of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new item3 ,sec4 #ghac4 ,authorization of appropriations4 4