This legislation introduces an annual tax on the net value of assets for individuals, effective for calendar years beginning after December 31, 2026. The tax applies to wealth exceeding a zero bracket threshold of $50 million. Assets between $50 million and $1 billion are taxed at 2%, while those above $1 billion face a 3% tax rate. Notably, the tax rate for assets exceeding $1 billion can increase to 6% if specific legislation establishing a comprehensive national health insurance program, which prohibits duplicate private benefits, is in effect. Married individuals are treated as a single taxpayer for this purpose. The bill also includes detailed rules for taxing various types of trusts, such as grantor and nongrantor multibeneficiary trusts, to ensure comprehensive coverage. The "net value of all taxable assets" includes all real, personal, tangible, and intangible property, wherever located, reduced by debts. Certain tangible personal property valued at $50,000 or less, not used in business or for income production, is excluded. The Secretary of the Treasury is mandated to establish valuation rules for all assets, including non-publicly traded ones, potentially using formulaic methods and addressing valuation discounts. Special provisions address deceased individuals, non-residents (taxing only U.S.-situated property), and covered expatriates, who face a 40% tax rate on lower brackets before expatriation. To ensure compliance, the bill requires annual audits of at least 30% of taxpayers subject to this tax. It also introduces accuracy-related penalties for substantial wealth tax valuation understatements, with increased penalties for gross misstatements. Furthermore, the legislation prohibits deducting the wealth tax from income taxes and allows for extensions of payment for up to five years in cases of severe liquidity constraints or undue hardship. It also strengthens disclosure requirements to prevent tax avoidance through foreign entities and authorizes significant appropriations for the Internal Revenue Service. This includes $70 billion for enforcement, $10 billion for taxpayer services, and $20 billion for business system modernization over fiscal years 2027 through 2037.
This legislation introduces an annual tax on the net value of assets for individuals, effective for calendar years beginning after December 31, 2026. The tax applies to wealth exceeding a zero bracket threshold of $50 million. Assets between $50 million and $1 billion are taxed at 2%, while those above $1 billion face a 3% tax rate. Notably, the tax rate for assets exceeding $1 billion can increase to 6% if specific legislation establishing a comprehensive national health insurance program, which prohibits duplicate private benefits, is in effect. Married individuals are treated as a single taxpayer for this purpose. The bill also includes detailed rules for taxing various types of trusts, such as grantor and nongrantor multibeneficiary trusts, to ensure comprehensive coverage. The "net value of all taxable assets" includes all real, personal, tangible, and intangible property, wherever located, reduced by debts. Certain tangible personal property valued at $50,000 or less, not used in business or for income production, is excluded. The Secretary of the Treasury is mandated to establish valuation rules for all assets, including non-publicly traded ones, potentially using formulaic methods and addressing valuation discounts. Special provisions address deceased individuals, non-residents (taxing only U.S.-situated property), and covered expatriates, who face a 40% tax rate on lower brackets before expatriation. To ensure compliance, the bill requires annual audits of at least 30% of taxpayers subject to this tax. It also introduces accuracy-related penalties for substantial wealth tax valuation understatements, with increased penalties for gross misstatements. Furthermore, the legislation prohibits deducting the wealth tax from income taxes and allows for extensions of payment for up to five years in cases of severe liquidity constraints or undue hardship. It also strengthens disclosure requirements to prevent tax avoidance through foreign entities and authorizes significant appropriations for the Internal Revenue Service. This includes $70 billion for enforcement, $10 billion for taxpayer services, and $20 billion for business system modernization over fiscal years 2027 through 2037.