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Annual Tax on Billionaires' Unrealized Gains and Closing Tax Loopholes

This bill mandates that the wealthiest Americans pay taxes annually on the increase in the value of their assets, even if those assets have not been sold. It aims to close legal loopholes that allow billionaires to defer tax payments indefinitely and avoid taxation when transferring wealth to heirs.
Key points
The new rules apply to taxpayers who met an income test of over $100 million or an asset test of over $1 billion for 3 consecutive years.
Tradable assets, such as stocks, will be taxed annually based on their market value increase (mark-to-market), rather than only upon sale.
Transferring assets via gift, bequest, or trust will be treated as a taxable sale.
An interest charge mechanism is introduced for the sale of nontradable assets to recoup the value of deferred taxes.
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Status: Introduced
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Additional Information
Print number: 119_S_2845
Sponsor: Sen. Wyden, Ron [D-OR]
Process start date: 2025-09-17