This bill introduces new provisions to the Internal Revenue Code targeting high-income taxpayers who have accumulated significant retirement account balances. It establishes a new limit on annual contributions to individual retirement plans (IRPs) for individuals meeting specific income and asset thresholds. Specifically, if a taxpayer's modified adjusted gross income exceeds certain amounts (e.g., $450,000 for joint filers) and their aggregate vested balance across all applicable retirement plans surpasses $10,000,000 , their IRP contributions will be restricted. The allowable contribution is capped at the amount by which their total balance falls short of the $10 million threshold, with rollover contributions and accounts acquired by death or divorce being exempt from this limitation. An excise tax will be imposed on contributions exceeding these new limits. Beyond contribution limits, the legislation also mandates increased minimum required distributions (MRDs) for these high-income, high-balance taxpayers. If an applicable taxpayer's total retirement assets exceed $10,000,000 , they will be subject to additional distribution requirements, which are calculated based on a percentage of the excess balance. For balances exceeding $20,000,000 (200% of the applicable dollar amount), a specific "applicable Roth excess amount" is determined and prioritized for distribution from Roth accounts. These increased MRDs are exempt from the typical 10% additional tax on early distributions, and plans must allow participants to elect these distributions. The bill defines "applicable retirement plans" broadly to include various defined contribution plans, annuity contracts, eligible deferred compensation plans, and individual retirement plans. Both the income thresholds for "applicable taxpayers" and the $10,000,000 aggregate balance threshold are subject to inflation adjustments in future years. The provisions regarding contribution limits and the associated excise tax will take effect for taxable years beginning after December 31, 2026 . The increased minimum required distribution requirements and related plan amendments will apply to taxable and plan years beginning after December 31, 2033 .
A bill to amend the Internal Revenue Code of 1986 to impose limitations on high-income taxpayers with large retirement account balances.
USA119th CongressS-5040| Senate
| Updated: 7/21/2026
This bill introduces new provisions to the Internal Revenue Code targeting high-income taxpayers who have accumulated significant retirement account balances. It establishes a new limit on annual contributions to individual retirement plans (IRPs) for individuals meeting specific income and asset thresholds. Specifically, if a taxpayer's modified adjusted gross income exceeds certain amounts (e.g., $450,000 for joint filers) and their aggregate vested balance across all applicable retirement plans surpasses $10,000,000 , their IRP contributions will be restricted. The allowable contribution is capped at the amount by which their total balance falls short of the $10 million threshold, with rollover contributions and accounts acquired by death or divorce being exempt from this limitation. An excise tax will be imposed on contributions exceeding these new limits. Beyond contribution limits, the legislation also mandates increased minimum required distributions (MRDs) for these high-income, high-balance taxpayers. If an applicable taxpayer's total retirement assets exceed $10,000,000 , they will be subject to additional distribution requirements, which are calculated based on a percentage of the excess balance. For balances exceeding $20,000,000 (200% of the applicable dollar amount), a specific "applicable Roth excess amount" is determined and prioritized for distribution from Roth accounts. These increased MRDs are exempt from the typical 10% additional tax on early distributions, and plans must allow participants to elect these distributions. The bill defines "applicable retirement plans" broadly to include various defined contribution plans, annuity contracts, eligible deferred compensation plans, and individual retirement plans. Both the income thresholds for "applicable taxpayers" and the $10,000,000 aggregate balance threshold are subject to inflation adjustments in future years. The provisions regarding contribution limits and the associated excise tax will take effect for taxable years beginning after December 31, 2026 . The increased minimum required distribution requirements and related plan amendments will apply to taxable and plan years beginning after December 31, 2033 .