,i #aaith ,,congress #ast ,session ,h4 ,r4 #biab ,,in ,,the ,,house ,,of ,,representatives ,april #ad1 #bjbe,ms4 ,lee of ,pennsylvania 7for herself1 ,ms4 ,tlaib1 ,mr4 ,nadler1 ,mr4 ,frost1 ,ms4 ,norton1 ,ms4 ,dean of ,pennsylvania1 ,mrs4 ,ramirez1 ,mr4 ,huffman1 ,mrs4 ,foushee1 and ,mrs4 ,watson ,coleman7 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 establish a wealth tax1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,oligarch ,act of #bjbe4 #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 any applicable taxpayer1 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 ,individuals ,in the case of an individual1 the tax imposed by this section shall be equal to the sum of-- 7,a7 #b percent of so much of the net value of all taxable assets of the taxpayer as exceed the threshold amount but do not exceed the product of #aj multiplied by threshold amount1 7,b7 #d percent of so much of the net value of all taxable assets of the taxpayer as exceed the product of #aj multiplied by the threshold amount but do not exceed the product of #ajj multiplied by the threshold amount1 7,c7 #f percent of so much of the net value of all taxable assets of the taxpayer as exceed the product of #ajj multiplied by the threshold amount but do not exceed the product of #a1jjj multiplied by the threshold amount1 plus 7,d7 #h percent of so much of the net value of all taxable assets of the taxpayer as exceed the product of #a1jjj multiplied by the threshold amount4 7#b7 ,trusts ,in the case of a trust1 the tax imposed by this section shall be equal to #h percent of so much of the net value of all taxable assets of the taxpayer as exceed the threshold amount4 7c7 ,applicable taxpayer 7#a7 ,in general ,the term applicable taxpayer means any individual or any trust 7other than a trust described in section #dja7;a7 and exempt from tax under section #eja7;a774 7#b7 ,treatment of married individuals ,for purposes of this section1 individuals who are married 7as defined in section #ggjc7 shall be treated as one applicable taxpayer4 7d7 ,threshold amount ,for purposes of this section1 the term threshold amount means the amount that is the product of #a1jjj multiplied by the greater of-- 7#a7 #ej1jjj1 or 7#b7 the applicable median household wealth4 7e7 ,applicable median household wealth ,the ,secretary shall annually determine the median household wealth with respect to the ,united ,states for purposes of this section4 7f7 ,application to trusts 7#a7 ,attribution of assets in trust ,in determining the assets of a taxpayer for purposes of subsection 7a73 7,a7 ,grantor trust ,in the case of a grantor trust1 the grantor shall be treated as holding all the assets of the trust4 7,b7 ,beneficiary trust ,in the case of a beneficiary trust1 each beneficiary of the trust shall be treated as holding a fraction of the assets of the trust in proportion to such beneficiary's interest in such trust4 7#b7 ,property of trusts ,any asset treated as held by a grantor or beneficiary under paragraph 7#a7 shall not be treated as held by the trust for purposes of this section4 7#c7 ,trusts relating to common beneficiaries ,trusts benefitting substantially the same beneficiaries shall be treated as a single applicable taxpayer for purposes of this section4 7#d7 ,definitions ,for purposes of this section3 7,a7 ,grantor trust ,the term grantor trust means a trust in which a taxpayer is treated as owning an asset of the trust under subpart ,e of part ,i of subchapter ,j of chapter #a4 7,b7 ,beneficiary trust ,the term beneficiary trust means any trust that is not a grantor trust4 7g7 ,regulations ,the ,secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section1 including-- 7#a7 regulations establishing a process by which a beneficiary may demonstrate the portion of such beneficiary's interest in a trust1 and 7#b7 regulations for determining the appropriate attribution of assets in a trust for purposes of subsection 7e77#a7 in the case of a trust with multiple grantors4 #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 excess of-- 7#a7 the value of all property of the taxpayer 7other than property excluded under subsection 7b771 real or personal1 tangible or intangible1 wherever situated1 over 7#b7 any debts 7including any debts secured by property excluded under subsection 7b77 owed by the taxpayer4 7b7 ,exclusion for certain assets under #ej1jjj ,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 subtitle3 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 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 #bija shall be applied by substituting the date of the applicable taxpayer's death for the last day of any 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 nonresident alien individual1 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 as if the calendar year ended on the day before the expatriation4 #bijd4 ,information reporting 7a7 ,in general ,not later than #ab months after the date of the enactment of this section1 the ,secretary shall by regulation 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 such ,code 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 such ,code is amended by adding at the end the following new paragraph3 7#c7 ,wealth tax 7,a7 ,in general ,in the case of an applicable 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 ,an applicable taxpayer is described in this subparagraph if such the ,secretary determines-- 7i7 the applicable taxpayer has severe liquidity constraints1 or 7ii7 immediate payment would cause undue hardship on an ongoing enterprise4 7,c7 ,applicable taxpayer ,for purposes of this paragraph1 the term applicable taxpayer has the meaning given such term in section #bija4 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 such ,code is amended by inserting after paragraph 7#aj7 the following new paragraph3 7#aa7 ,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 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#aa7 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 ,exemption of tax-,exempt entities ,section #eja7;a7 of such ,code is amended by inserting and subtitle ,b-#a after this subtitle4 7f7 ,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 7g7 ,effective date ,the amendments made by this section shall apply to calendar years beginning after the date of the enactment of this ,act4