,,ii #aaith ,,congress #b;d ,session ,s4 #cicj ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,february #bf1 #bjbf,mr4 ,merkley 7for himself and ,mr4 ,hawley7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to impose an excise tax on the acquisition of single-family residences by hedge fund taxpayers1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,,hope 7,humans over ,private ,equity7 for ,homeownership ,act4 #b4 ,excise tax on acquisition of single-family residences by hedge fund taxpayers 7a7 ,in general ,subtitle ,d of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new chapter3 #ej;,b ,single-family residences ,sec4 #ejjj;,e4 ,newly acquired single-family residences4 #ejjj;,e4 ,newly acquired single-family residences 7a7 ,in general ,there is hereby imposed the acquisition of any newly acquired single-family residence by a hedge fund taxpayer an amount equal to #ae percent of the purchase price thereof4 7b7 ,newly acquired single-,family residence ,for purposes of this section-- 7#a7 ,in general ,the term newly acquired single-family residence means any residential property which-- 7,a7 consists of #a-to-#d dwelling units1 and 7,b7 was acquired by the taxpayer in any taxable year which begins after the date of the enactment of this chapter4 7#b7 ,exception ,a residential property shall not be treated as a newly acquired single-family residence if1 immediately after acquisition and at all times thereafter1 such property is-- 7,a7 not rented or leased1 and 7,b7 used as the principal residence 7within the meaning of section #aba7 of any person who has an ownership interest in the hedge fund taxpayer acquiring such taxpayer4 7c7 ,hedge fund taxpayer ,for purposes of this chapter-- 7#a7 ,in general ,the term hedge fund taxpayer means1 with respect to any taxable year1 any applicable entity which-- 7,a7 manages funds pooled from investors1 7,b7 has #ej1jjj1jjj or more in net value or assets under management on any day during the taxable year1 and 7,c7 is a fiduciary with respect to such investors4 7#b7 ,applicable entity 7,a7 ,in general ,the term applicable entity means-- 7i7 any partnership1 7ii7 any corporation1 or 7iii7 any real estate investment trust4 7,b7 ,exceptions ,the term applicable entity shall not include-- 7i7 an organization which is described in section #eja7;c77#c7 and exempt from tax under section #eja7;a71 or 7ii7 an organization which is primarily engaged in the construction or rehabilitation of single-family residences and which offers such residences for sale in the ordinary course of business4 7#c7 ,aggregation rules 7,a7 ,in general ,all persons which are treated as a single employer under subsections 7a7 and 7b7 of section #eb shall be treated as a single person4 7,b7 ,modifications ,for purposes of this subsection-- 7i7 section #eb7;a7 shall be applied by substituting component members for members1 and 7ii7 for purposes of applying section #eb7;b71 the term trade or business shall include any activity treated as a trade or business under paragraph 7#e7 or 7#f7 of section #dfi7;c7 7determined without regard to the phrase ,to the extent provided in regulations in such paragraph 7#f774 7,c7 ,component member ,for purposes of this paragraph1 the term component member has the meaning given such term by section #aefc7;b71 except that the determination shall be made without regard to section #aefc7;b77#b74 7d7 ,other definitions and rules ,for purposes of this section-- 7#a7 ,purchase price ,the term purchase price means the adjusted basis of the newly acquired single-family residence on the date such residence is purchased4 7#b7 ,acquisition ,a hedge fund taxpayer shall be treated as acquiring a single-family residence if the taxpayer acquires a majority ownership interest in the single-family residence1 regardless of the percentage of that ownership interest4 4 7b7 ,clerical amendment ,the table of chapters for subtitle ,d of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new item3 ,chapter #ej;,b--,excess single-family residences 4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after the date of enactment of this ,act4 #c4 ,corporate surtax on hedge fund taxpayers 7a7 ,in general ,section #aa of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7e7 ,hedge fund taxpayers ,in the case of a corporation which is described in section #ejjj;,e7c71 the percentage under subsection 7b7 shall be increased by #e percentage points4 4 7b7 ,effective date ,the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjce4 #d4 ,disallowance of certain deductions taken in connection with single-family residences of hedge fund taxpayers 7a7 ,mortgage interest 7#a7 ,in general ,section #afc of the ,internal ,revenue ,code of #aihf is amended by redesignating subsection 7n7 as subsection 7o7 and by inserting after subsection 7m7 the following new subsection3 7n7 ,no deduction for interest on acquisition indebtedness of single-,family residences of certain taxpayers 7#a7 ,in general ,in the case of a hedge fund taxpayer1 no deduction shall be allowed under this chapter with respect to interest paid or accrued on acquisition indebtedness with respect to any single-family residence4 7#b7 ,definitions ,for purposes of this subsection-- 7,a7 ,hedge fund taxpayer ,the term hedge fund taxpayer means1 for any taxable year1 any taxpayer-- 7i7 who is described in section #ejjj;,e7c71 and 7ii7 who is in the trade or business of renting or leasing single-family residences4 7,b7 ,acquisition indebtedness ,the term acquisition indebtedness has the meaning given such term under subsection 7h77#c77;,b71 determined-- 7i7 by substituting single-family residence 7as defined in subsection 7n77 for qualified residence1 and 7ii7 without regard to clause 7ii7 thereof4 7,c7 ,single-family residence ,the term single-family residence means any residential property which consists of #a-to-#d dwelling units4 4 7#b7 ,effective date ,the amendments made by this subsection shall apply to taxable years beginning after ,december #ca1 #bjcj4 7b7 ,depreciation 7#a7 ,in general ,section #afg of the ,internal ,revenue ,code of #aihf is amended by redesignating subsection 7i7 as subsection 7j7 and by inserting after subsection 7h7 the following new subsection3 7i7 ,deduction disallowed for single-,family residences of certain taxpayers 7#a7 ,in general ,in the case of a hedge fund taxpayer1 no deduction shall be allowed under this section for any single-family residence4 7#b7 ,definitions ,for purposes of this subsection-- 7,a7 ,hedge fund taxpayer ,the term hedge fund taxpayer means1 for any taxable year1 any taxpayer-- 7i7 who is described in section #ejjj;,e7c71 and 7ii7 who is in the trade or business of renting or leasing single-family residences4 7,b7 ,single-family residence ,the term single-family residence means any residential property which consists of #a-to-#d dwelling units4 4 7#b7 ,effective date ,the amendments made by this subsection shall apply to taxable years beginning after ,december #ca1 #bjcj4 7c7 ,qualified business income 7#a7 ,in general ,section #aii;,a7d77#a7 of the ,internal ,revenue ,code of #aihf is amended by striking or at the end of subparagraph 7,a71 by striking the period at the end of subparagraph 7,b7 and inserting 1 or1 and by adding at the end the following new subparagraph3 7,c7 any trade or business of hedge fund taxpayer 7as defined in section #afc7n77#b77;,a774 4 7#b7 ,effective date ,the amendments made by this subsection shall apply to taxable years beginning after ,december #ca1 #bjce4