This bill aims to amend the Internal Revenue Code to ensure that high net-worth individuals cannot avoid paying taxes on their income and assets. Its primary mechanism is to treat certain loans and long-term leases as deemed sales of appreciated capital assets for tax purposes, thereby accelerating the recognition of capital gains. The legislation introduces a new section requiring that when an "applicable taxpayer" receives a loan, an equivalent amount of their long-term capital assets is considered sold at fair market value on the last day of the taxable year the loan was issued. This triggers a capital gains tax liability, and importantly, these gains cannot be reduced or offset by any long-term capital losses. Long-term leases (over five years) are similarly treated as loans, with the property's fair market value acting as the loan amount. An "applicable taxpayer" is defined as an individual who has met either an income test (over $100 million in adjusted gross income) or an asset test (over $1 billion in covered assets) for each of the three preceding taxable years. This status also extends to certain trusts and estates meeting similar, albeit lower, financial thresholds. Special rules address married individuals, foreign persons, and expatriates, alongside conditions for terminating applicable taxpayer status. The bill broadly defines "covered assets" to include both tradable assets (e.g., those on established markets) and nontradable assets (e.g., interests in savings plans, cash, private placement life insurance). Valuation rules are specified for these assets, and the aggregate value is reduced by the taxpayer's indebtedness and other liabilities. Anti-avoidance provisions ensure that loans made to pass-through entities, such as partnerships and S corporations, are attributed pro rata to their owners, subjecting applicable taxpayer owners to the deemed sale rules. The Secretary of the Treasury is mandated to prescribe regulations and guidance for implementing these provisions, including rules for compliance assistance and reporting requirements. These amendments are set to apply to taxable years beginning after December 31, 2026.