I 

118TH CONGRESS 

2D SESSION H. R. 10028 

To amend the Internal Revenue Code of 1986 to disallow the deduction 

of certain expenses relating to ownership of single-family homes by specified large investors, to impose an excise tax on the sale of such homes 

by such investors, and to prohibit Federal mortgage assistance relating 

to certain large investors. 

IN THE HOUSE OF REPRESENTATIVES 

OCTOBER 22, 2024 

Mr. KHANNA (for himself, Ms. PORTER, Mr. TAKANO, Mr. GRIJALVA, Mr. 

FROST, Mrs. CHERFILUS-MCCORMICK, Mrs. WATSON COLEMAN, Mr. 

JACKSON of Illinois, Mr. DELUZIO, and Ms. LEE of California) introduced the following bill; which was referred to the Committee on Ways 

and Means, and in addition to the Committee on Financial Services, for 

a period to be subsequently determined by the Speaker, in each case for 

consideration of such provisions as fall within the jurisdiction of the committee concerned 

A BILL 

To amend the Internal Revenue Code of 1986 to disallow 

the deduction of certain expenses relating to ownership 

of single-family homes by specified large investors, to 

impose an excise tax on the sale of such homes by 

such investors, and to prohibit Federal mortgage assistance relating to certain large investors. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 


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1 SECTION 1. SHORT TITLE. 

2 This Act may be cited as the ‘‘Stop Wall Street Land3 lords Act of 2024’’. 

4 SEC. 2. DISALLOWANCE OF DEDUCTION OF CERTAIN EX5 PENSES RELATED TO SINGLE-FAMILY HOMES 

6 HELD BY SPECIFIED LARGE INVESTORS. 

7 (a) IN GENERAL.—Part IX of subchapter B of Chap8 ter 1 of subtitle A of the Internal Revenue Code of 1986 

9 is amended by adding at the end the following new section: 

10 ‘‘SEC. 280I. CERTAIN EXPENSES RELATED TO SINGLE-FAM11 ILY HOMES HELD BY SPECIFIED LARGE IN12 VESTORS. 

13 ‘‘(a) IN GENERAL.—In the case of a specified large 

14 investor, no deduction shall be allowed under this chapter 

15 for the following expenses relating to the ownership of a 

16 single-family home: 

17 ‘‘(1) Amounts paid or incurred for the interest 

18 on a mortgage relating to such single-family home or 

19 to insure such single-family home. 

20 ‘‘(2) Depreciation of such single-family home. 

21 ‘‘(b) SPECIFIED LARGE INVESTOR.—For purposes of 

22 this section— 

23 ‘‘(1) IN GENERAL.—The term ‘specified large 

24 investor’ means any person for any taxable year if 

25 the aggregate fair market value of all assets of such 

26 person (reduced by the aggregate debts of the taxVerDate Sep 11 2014 18:59 Nov 12, 2024 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\H10028.IH H10028

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1 payer) exceeds $100,000,000 at any time during 

2 such taxable year. 

3 ‘‘(2) TREATMENT OF CONTROLLED GROUPS.— 

4 For purposes of this subsection— 

5 ‘‘(A) IN GENERAL.—All persons which are 

6 part of a controlled group (within the meaning 

7 of section 1563(a) applied by substituting ‘more 

8 than 50 percent’ for ‘at least 80 percent’ each 

9 place it appears) shall be treated as 1 person. 

10 ‘‘(B) NONINCORPORATED PERSONS UNDER

11 COMMON CONTROL.—Under regulations or 

12 other guidance provided by the Secretary, prin13 ciples similar to the principles of subparagraph 

14 (A) shall apply to a group of persons under 

15 common control where 1 or more of such per16 sons is not a corporation. 

17 ‘‘(3) GOVERNMENT ENTITIES AND CERTAIN

18 TAX-EXEMPT ENTITIES.—Such term shall not in19 clude either of the following: 

20 ‘‘(A) Any governmental entity. 

21 ‘‘(B) Any organization which is described 

22 in section 501(c)(3) and exempt from tax under 

23 section 501(a). 

24 ‘‘(c) SINGLE-FAMILY HOME.— 


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1 ‘‘(1) IN GENERAL.—For purposes of this sec2 tion, the term ‘single-family home’ means any real 

3 property located in the United States if such prop4 erty includes at least 1 dwelling unit and not more 

5 than 4 dwelling units. 

6 ‘‘(2) EXCEPTION FOR FEDERALLY-ASSISTED

7 BUILDINGS.—For purposes of this section— 

8 ‘‘(A) IN GENERAL.—Such term shall not 

9 include any federally-assisted building. 

10 ‘‘(B) FEDERALLY-ASSISTED BUILDING.— 

11 The term ‘federally-assisted building’ means 

12 any building— 

13 ‘‘(C) which is substantially assisted, fi14 nanced, or operated under section 8 of the 

15 United States Housing Act of 1937, section 

16 221(d)(3), 221(d)(4), or 236 of the National 

17 Housing Act, section 515 of the Housing Act of 

18 1949, or any other housing program adminis19 tered by the Department of Housing and Urban 

20 Development or by the Rural Housing Service 

21 of the Department of Agriculture, 

22 ‘‘(D) with respect to which a credit is al23 lowed to the taxpayer under section 42, or 


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1 ‘‘(E) for which financing is provided by a 

2 qualified bond (within the meaning of section 

3 141). 

4 ‘‘(d) EXCEPTIONS.— 

5 ‘‘(1) PRINCIPAL RESIDENCE.—In the case of a 

6 specified large investor who is an individual, sub7 section (a) shall not apply to any single-family home 

8 if such home is used as the principal residence of 

9 such investor. 

10 ‘‘(2) ORIGINAL CONSTRUCTION OR SUBSTAN11 TIAL REHABILITATION.—Subsection (a) shall not 

12 apply with respect to a single-family home originally 

13 constructed or substantially rehabilitated (as defined 

14 in section 47(c)) by the taxpayer.’’. 

15 (b) CLERICAL AMENDMENT.—The table of sections 

16 for part IX of subchapter B of chapter 1 of such Code 

17 is amended by inserting after the item relating to section 

18 280H the following new item: 

‘‘Sec. 280I. Certain expenses related to single-family homes held by specified 

large investors.’’. 

19 (c) EFFECTIVE DATE.—The amendments made by 

20 this section shall apply to amounts paid or incurred and 

21 depreciation that occurs after the date that is 18 months 

22 after the date of the enactment of this Act. 


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1 SEC. 3. EXCISE TAX ON TRANSFERS OF SINGLE-FAMILY 

2 HOMES BY SPECIFIED LARGE INVESTORS. 

3 (a) IN GENERAL.—Subchapter C of chapter 36 of 

4 subtitle D of the Internal Revenue Code of 1986 is amend5 ed to read as follows: 

6 ‘‘Subchapter C—Tax on Transfers of Single7 Family Homes by Specified Large Investors 

‘‘Sec. 4471. Tax on transfers of single-family homes by specified large investors. 

8 ‘‘SEC. 4471. TAX ON TRANSFERS OF SINGLE-FAMILY HOMES 

9 BY SPECIFIED LARGE INVESTORS. 

10 ‘‘(a) IN GENERAL.—There is hereby imposed a tax 

11 on the sale or transfer of a single-family home by a speci12 fied large investor in an amount equal to the sale price 

13 of the single-family home. 

14 ‘‘(b) SPECIFIED LARGE INVESTOR; SINGLE-FAMILY

15 HOME.—For purposes of this section, the terms ‘specified 

16 large investor’ and ‘single-family home’ shall have the re17 spective meanings given such terms in section 280I. 

18 ‘‘(c) SPECIAL RULES.—Rules similar to the rules of 

19 subsections (b)(2), (d)(1), and (d)(2) of 280I shall apply 

20 for purposes of this section.’’. 

21 (b) CLERICAL AMENDMENT.—The table of sub22 chapters for chapter 36 of subtitle D of such Code is 

23 amended by adding after the item relating to subchapter 

24 B the following new item: 


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‘‘SUBCHAPTER C. Tax on transfers of single family homes by 

specified large investors.’’. 

1 (c) EFFECTIVE DATE.—The amendments made by 

2 this section shall apply to sales and transfers occurring 

3 after the date that is 18 months after the date of the en4 actment of this Act. 

5 SEC. 4. LOW-INCOME HOUSING ASSISTANCE. 

6 (a) DEPOSIT OF FUNDS.—There are hereby trans7 ferred to the Housing Trust Fund established under sec8 tion 1338 of the Federal Housing Enterprises Financial 

9 Safety and Soundness Act of 1992 (12 U.S.C. 4568) 

10 amounts equivalent to the taxes received in the Treasury 

11 under section 4471 of the Internal Revenue Code of 1986. 

12 (b) USE OF FUNDS.—To the extent provided for in 

13 advance in appropriations Acts, the amounts deposited in 

14 the Fund pursuant to subsection (a) shall be used to in15 crease and preserve the supply of rental housing afford16 able to extremely low- and very low-income families, in17 cluding homeless families, in accordance with such section 

18 1338. 

19 SEC. 5. PROHIBITIONS ON FEDERAL MORTGAGE ASSIST20 ANCE. 

21 (a) FANNIE MAE AND FREDDIE MAC.—Subpart A of 

22 part 2 of subtitle A of title XIII of the Housing and Com23 munity Development Act of 1992 (12 U.S.C. 4541 et seq.) 

24 is amended by adding at the end the following new section: 


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1 ‘‘SEC. 1329. PROHIBITION RELATING TO SPECIFIED LARGE 

2 INVESTORS. 

3 ‘‘The Director shall, by regulation, prohibit the enter4 prises from newly purchasing any mortgage on a single5 family housing or any portion thereof (or any interest in 

6 such a mortgage), and from newly lending on the security 

7 of or securitizing any such mortgage under which the 

8 mortgagee is a specified large investor (as such term is 

9 defined in section 280I of the Internal Revenue Code of 

10 1986).’’. 

11 (b) GINNIE MAE.—Section 302(c) of the National 

12 Housing Act (12 U.S.C. 1717(c)) is amended by adding 

13 at the end the following new paragraph: 

14 ‘‘(6) The Association may not newly guarantee 

15 the payment of principal of or interest on any trust 

16 certificate or other security based or backed by a 

17 trust or pool that contains, or purchase or acquire, 

18 any mortgage under which the mortgagee is a speci19 fied large investor (as such term is defined in section 

20 280I of the Internal Revenue Code of 1986).’’. 

Æ 


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