I 

118TH CONGRESS 

2D SESSION H. R. 7749 

To amend the Internal Revenue Code of 1986 to impose a tax on the 

net value of assets of a taxpayer, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

MARCH 20, 2024 

Ms. JAYAPAL (for herself, Mr. BOYLE of Pennsylvania, Mr. BEYER, Mr. BOWMAN, Ms. BUSH, Ms. CHU, Mr. DAVIS of Illinois, Mr. EVANS, Mr. 

GARCI ́A of Illinois, Mr. GOLDMAN of New York, Mr. GRIJALVA, Mr. IVEY, 

Mr. JACKSON of Illinois, Mr. JOHNSON of Georgia, Ms. LEE of California, Ms. LEE of Pennsylvania, Mr. MCGOVERN, Mr. NADLER, Ms. 

NORTON, Ms. OCASIO-CORTEZ, Ms. OMAR, Ms. PORTER, Ms. PRESSLEY, 

Mrs. RAMIREZ, Ms. SCHAKOWSKY, Mr. SCHIFF, Mr. SMITH of Washington, Mr. TAKANO, Ms. TLAIB, Ms. TOKUDA, Mr. TRONE, Ms. 

WATERS, Mrs. WATSON COLEMAN, and Ms. WILD) introduced the following bill; which was referred to the Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to impose 

a tax on the net value of assets of a taxpayer, and 

for other purposes. 

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

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Ultra-Millionaire Tax 

5 Act of 2024’’. 


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1 SEC. 2. IMPOSITION OF WEALTH TAX. 

2 (a) IN GENERAL.—The Internal Revenue Code of 

3 1986 is amended by inserting after subtitle B the fol4 lowing new subtitle: 

5 ‘‘Subtitle B–1—Wealth Tax 

‘‘CHAPTER 18—DETERMINATION OF WEALTH TAX

6 ‘‘CHAPTER 18—DETERMINATION OF 

7 WEALTH TAX 

‘‘Sec. 2901. Imposition of tax. 

‘‘Sec. 2902. Net value of taxable assets. 

‘‘Sec. 2903. Special rules. 

‘‘Sec. 2904. Information reporting. 

‘‘Sec. 2905. Enforcement. 

8 ‘‘SEC. 2901. IMPOSITION OF TAX. 

9 ‘‘(a) IN GENERAL.—In the case of an individual, a 

10 tax is hereby imposed on the net value of all taxable assets 

11 of the taxpayer on the last day of any calendar year. 

12 ‘‘(b) COMPUTATION OF TAX.— 

13 ‘‘(1) IN GENERAL.—The tax imposed by this 

14 section shall be equal to the sum of— 

15 ‘‘(A) 0 percent of so much of the net value 

16 of all taxable assets of the taxpayer as does not 

17 exceed the zero bracket threshold, 

18 ‘‘(B) 2 percent of so much of the net value 

19 of all taxable assets of the taxpayer in excess of 

20 the zero bracket threshold but not in excess of 

21 the top bracket threshold, plus 


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1 ‘‘(C) the applicable percentage of so much 

2 of the net value of all such taxable assets of the 

3 taxpayer in excess of the top bracket threshold. 

4 ‘‘(2) ZERO BRACKET THRESHOLD; TOP BRACK5 ET THRESHOLD.—For purposes of this section— 

6 ‘‘(A) ZERO BRACKET THRESHOLD.—The 

7 zero bracket threshold is $50,000,000. 

8 ‘‘(B) TOP BRACKET THRESHOLD.—The 

9 top bracket threshold is $1,000,000,000. 

10 ‘‘(c) APPLICABLE PERCENTAGE.— 

11 ‘‘(1) IN GENERAL.—For purposes of this sec12 tion, the applicable percentage is— 

13 ‘‘(A) except as provided in subparagraph 

14 (B), 3 percent, and 

15 ‘‘(B) in the case of any calendar year in 

16 which there is in effect legislation which meets 

17 the requirements of paragraph (2), 6 percent. 

18 ‘‘(2) LEGISLATION DESCRIBED.—Legislation 

19 meets the requirements of this paragraph if such 

20 legislation— 

21 ‘‘(A) establishes a health insurance pro22 gram that provides to all residents of the 

23 United States comprehensive protection against 

24 the costs of health care and health-related serv25 ices, and 


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1 ‘‘(B) prohibits private entities from pro2 viding duplicate benefits. 

3 ‘‘(d) TREATMENT OF MARRIED INDIVIDUALS.—For 

4 purposes of this section, individuals who are married (as 

5 defined in section 7703) shall be treated as one taxpayer. 

6 ‘‘(e) TREATMENT OF NONGRANTOR MULTIBENE7 FICIARY TRUSTS.— 

8 ‘‘(1) IN GENERAL.—Any trust or portion of a 

9 trust which is a nongrantor multibeneficiary trust 

10 shall be treated as an individual to whom this chap11 ter applies. 

12 ‘‘(2) COMPUTATION OF TAX.— 

13 ‘‘(A) IN GENERAL.—In applying this chap14 ter to a nongrantor multibeneficiary trust— 

15 ‘‘(i) the zero bracket threshold shall 

16 be equal to the sum of— 

17 ‘‘(I) $0, plus 

18 ‘‘(II) the lowest unused 0 percent 

19 bracket amount assigned to the trust 

20 by all beneficiaries of the trust, and 

21 ‘‘(ii) the top bracket threshold shall be 

22 equal to the sum of— 

23 ‘‘(I) $0, plus 


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1 ‘‘(II) the lowest unused 2 percent 

2 bracket amount assigned to the trust 

3 by all beneficiaries of the trust. 

4 ‘‘(B) UNUSED 0 PERCENT BRACKET

5 AMOUNT.—For purposes of this paragraph, the 

6 term ‘unused 0 percent bracket amount’ means, 

7 with respect to any beneficiary for any calendar 

8 year, the lesser of— 

9 ‘‘(i) the excess (if any) of— 

10 ‘‘(I) the zero bracket threshold, 

11 over 

12 ‘‘(II) the sum of— 

13 ‘‘(aa) the net value of all 

14 taxable assets of the beneficiary 

15 for the calendar year, plus 

16 ‘‘(bb) any unused 0 percent 

17 bracket amount assigned by the 

18 beneficiary to other nongrantor 

19 multibeneficiary trusts, or 

20 ‘‘(ii) the portion of the net value of all 

21 taxable assets of the trust which such ben22 eficiary is eligible to receive. 

23 ‘‘(C) UNUSED 2 PERCENT BRACKET

24 AMOUNT.—For purposes of this paragraph, the 

25 term ‘unused 2 percent bracket amount’ means, 


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1 with respect to any beneficiary for any calendar 

2 year, the lesser of— 

3 ‘‘(i) the excess (if any) of— 

4 ‘‘(I) the top bracket threshold re5 duced by the zero bracket threshold, 

6 over 

7 ‘‘(II) the sum of— 

8 ‘‘(aa) the net value of all 

9 taxable assets of the beneficiary 

10 for the calendar year in excess of 

11 the zero bracket threshold, plus 

12 ‘‘(bb) any unused 2 percent 

13 bracket amount assigned by the 

14 beneficiary to other nongrantor 

15 multibeneficiary trusts, or 

16 ‘‘(ii) the portion of the net value of all 

17 taxable assets of the trust which such ben18 eficiary is eligible to receive. 

19 ‘‘(D) ASSIGNMENT OF AMOUNTS.—The as20 signment of any amount of unused 0 percent 

21 bracket amount and unused 2 percent bracket 

22 amount shall be made at such time and in such 

23 manner as specified by the Secretary in regula24 tions. In any case in which no affirmative asVerDate Sep 11 2014 19:28 Apr 04, 2024 Jkt 049200 PO 00000 Frm 00006 Fmt 6652 Sfmt 6201 E:\BILLS\H7749.IH H7749

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1 signment is made by a beneficiary, the amount 

2 assigned shall be $0. 

3 ‘‘(3) NONGRANTOR MULTIBENEFICIARY

4 TRUST.—For purposes of this chapter— 

5 ‘‘(A) IN GENERAL.—The term ‘nongrantor 

6 multibeneficiary trust’ means any trust or por7 tion of a trust— 

8 ‘‘(i) with respect to which no person is 

9 treated as an owner under subpart E of 

10 subchapter J of chapter 1, 

11 ‘‘(ii) no property of which is attrib12 utable to a gratuitous transfer of assets by 

13 a person who is subject to tax under this 

14 chapter for the calendar year, and 

15 ‘‘(iii) which has more than one bene16 ficiary (determined as of the last day of 

17 the calendar year). 

18 ‘‘(B) EXCEPTION.—Such term shall not in19 clude— 

20 ‘‘(i) any trust described in section 

21 401(a) and exempt from tax under section 

22 501(a), 

23 ‘‘(ii) any trust all of the unexpired in24 terests in which are devoted to one or more 


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1 of the purposes described in section 

2 170(c)(2)(B), 

3 ‘‘(iii) any charitable lead annuity trust 

4 (as defined in section 2642(e)(3)) or chari5 table lead unitrust, or 

6 ‘‘(iv) any charitable annuity remain7 der trust (as defined in section 664(d)(1)) 

8 or any charitable remainder unitrust (as 

9 defined in section 664(d)(2)). 

10 ‘‘(C) BENEFICIARY.—The term ‘bene11 ficiary’ shall not include any person whose in12 terest in a trust is contingent on the death of 

13 another person with an interest in such trust. 

14 ‘‘SEC. 2902. NET VALUE OF TAXABLE ASSETS. 

15 ‘‘(a) IN GENERAL.—For purposes of this subtitle, the 

16 term ‘net value of all taxable assets’ means, as of any date, 

17 the value of all property of the taxpayer (other than prop18 erty excluded under subsection (b)), real or personal, tan19 gible or intangible, wherever situated, reduced by any 

20 debts (including any debts secured by property excluded 

21 under subsection (b)) owed by the taxpayer. 

22 ‘‘(b) EXCLUSION FOR CERTAIN ASSETS.—Property 

23 of the taxpayer shall not be taken into account under sub24 section (a) if such property— 


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1 ‘‘(1) has a value of $50,000 or less (determined 

2 without regard to any debt owed by the taxpayer 

3 with respect to such property), 

4 ‘‘(2) is tangible personal property, and 

5 ‘‘(3) is not property— 

6 ‘‘(A) which is used in a trade or business 

7 of the taxpayer, 

8 ‘‘(B) in connection with which a deduction 

9 is allowable under section 212, or 

10 ‘‘(C) which is a collectible as defined in 

11 section 408(m), a boat, an aircraft, a mobile 

12 home, a trailer, a vehicle, or an antique or other 

13 asset that maintains or increases its value over 

14 time (within the meaning of section 5.02(2) of 

15 Revenue Procedure 2018–08). 

16 ‘‘(c) RULES FOR DETERMINING PROPERTY OF THE

17 TAXPAYER.—For purposes of this subtitle— 

18 ‘‘(1) PROPERTY INCLUDED IN ESTATE.—Any 

19 property that would be included in the estate of the 

20 taxpayer if the taxpayer died shall be treated as 

21 property of the taxpayer. 

22 ‘‘(2) INCLUSION OF CERTAIN GIFTS.—Any 

23 property transferred by the taxpayer after the date 

24 of the enactment of this chapter, to an individual 

25 who is a member of the family of the taxpayer (as 


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1 determined under section 267(c)(4)) and has not at2 tained the age of 18 shall be treated as property of 

3 the taxpayer for any calendar year before the year 

4 in which such individual attains the age of 18. 

5 ‘‘(3) ATTRIBUTION OF PROPERTY HELD BY

6 TRUSTS.— 

7 ‘‘(A) GRANTOR TRUSTS.—If an individual 

8 is treated as the owner of any portion of a trust 

9 under subpart E of subchapter J of chapter 1, 

10 property attributable to such trust or portion of 

11 the trust shall be treated as property of the in12 dividual and not as property of the trust. 

13 ‘‘(B) NONGRANTOR TRUSTS.— 

14 ‘‘(i) IN GENERAL.—In the case of a 

15 trust or portion of a trust which is not de16 scribed in subparagraph (A), any property 

17 which is attributable to a gratuitous trans18 fer of assets by an individual who is sub19 ject to tax under this chapter for the cal20 endar year shall be treated as property of 

21 such individual and not as property of the 

22 trust. 

23 ‘‘(ii) OTHER TRUSTS.— 

24 ‘‘(I) IN GENERAL.—In the case 

25 of any trust or portion of a trust 


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1 which is described in subclause (II), 

2 the property of such trust shall be 

3 treated as the property of the bene4 ficiary of such trust and not as the 

5 property of the trust. 

6 ‘‘(II) TRUSTS TO WHICH THIS

7 SUBCLAUSE APPLIES.—A trust is de8 scribed in this subclause if such trust 

9 not described in subparagraph (A), 

10 the assets of such trust are not attrib11 utable to a gratuitous transfer of as12 sets by a person who is subject to tax 

13 under this chapter for the calendar 

14 year, and such trust has a single ben15 eficiary (determined as of the last day 

16 of the calendar year). 

17 ‘‘(C) RIGHT OF RECOVERY.— 

18 ‘‘(i) IN GENERAL.—If any part of the 

19 net value of taxable assets of an individual 

20 on which tax has been paid consists of the 

21 value of property held by a trust which is 

22 included in the net value of taxable assets 

23 of such individual by reason of subpara24 graph (B), then such individual shall be 

25 entitled to recover from the trust the 


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1 amount which bears the same ratio to the 

2 recoverable amount as— 

3 ‘‘(I) the value of such property, 

4 bears to 

5 ‘‘(II) the net value of taxable as6 sets of the taxpayer. 

7 ‘‘(ii) RECOVERABLE AMOUNT.—For 

8 purposes of clause (i), the recoverable 

9 amount with respect to any trust is the ex10 cess of— 

11 ‘‘(I) the tax imposed under this 

12 chapter for the calendar year on the 

13 individual, over 

14 ‘‘(II) the amount of such tax 

15 which would be imposed for such cal16 endar year on such individual if no 

17 property held by such trust were in18 cluded in the net value of taxable as19 sets of the individual. 

20 ‘‘(iii) TREATMENT WHERE NO RECOV21 ERY.—In any case where a trust does not 

22 reimburse any taxpayer as provided in 

23 clause (i), the taxpayer shall be treated for 

24 purposes of this chapter as having made a 

25 gratuitous transfer to the trust in an 


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1 amount equal to the amount determined 

2 under clause (i). Such transfer shall be 

3 treated as having been made on the last 

4 day of the calendar year for which the tax 

5 under subsection (a) was due. 

6 ‘‘(4) TREATMENT OF ASSETS HELD BY CERTAIN

7 SPLIT-INTEREST TRUSTS.— 

8 ‘‘(A) REMAINDER INTERESTS IN CHARI9 TABLE REMAINDER ANNUITY TRUSTS AND

10 CHARITABLE REMAINDER UNITRUSTS.—In the 

11 case of any charitable remainder annuity trust 

12 (as defined in section 664(d)(1)) or of a chari13 table remainder unitrust (as defined in section 

14 664(d)(2))— 

15 ‘‘(i) the present value of any remain16 der interest shall not be taken into account 

17 under subsection (a), and 

18 ‘‘(ii) the present value of any other in19 terests shall be taken in account under 

20 subsection (a), in accordance with regula21 tions promulgated by the Secretary, as the 

22 property of the beneficiaries of such inter23 ests. 

24 ‘‘(B) CHARITABLE LEAD ANNUITY TRUSTS

25 AND CHARITABLE LEAD UNITRUSTS.—In the 


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1 case of a charitable lead annuity trust (as de2 fined in section 2642(e)(3)) or a charitable lead 

3 unitrust— 

4 ‘‘(i) the present value of any interest 

5 described in section 2522(c)(2)(B) shall 

6 not be taken into account under subsection 

7 (a), and 

8 ‘‘(ii) notwithstanding paragraphs (A) 

9 and (B) of paragraph (3), the present 

10 value of any remainder interest shall be 

11 taken into account under subsection (a), in 

12 accordance with regulations promulgated 

13 by the Secretary, as the property of the 

14 beneficiaries of such remainder interest. 

15 ‘‘(d) ESTABLISHMENT OF VALUATION RULES.—Not 

16 later than 12 months after the date of the enactment of 

17 this section, the Secretary shall establish rules and meth18 ods for determining the value of any asset for purposes 

19 of this subtitle, including rules for the valuation of assets 

20 that are not publicly traded or that do not have a readily 

21 ascertainable value. Such rules and methods— 

22 ‘‘(1) may utilize retrospective and prospective 

23 formulaic valuation methods not currently in use by 

24 the Secretary, 


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1 ‘‘(2) may require the use of formulaic valuation 

2 approaches for designated assets, including 

3 formulaic approaches based on proxies for deter4 mining presumptive valuations, formulaic approaches 

5 based on prospective adjustments from purchase 

6 prices or other prior events, or formulaic approaches 

7 based on retrospectively adding deferral charges 

8 based on eventual sale prices or other specified later 

9 events indicative of valuation, and 

10 ‘‘(3) may address the use of valuation dis11 counts. 

12 ‘‘SEC. 2903. SPECIAL RULES. 

13 ‘‘(a) DECEASED INDIVIDUALS.— 

14 ‘‘(1) IN GENERAL.—In the case of any indi15 vidual who dies during a calendar year and who is 

16 not married on the date of such individual’s death— 

17 ‘‘(A) section 2901(a) shall be applied by 

18 substituting ‘the date of the individual’s death’ 

19 for ‘the last day of the calendar year’, and 

20 ‘‘(B) the amount of the tax imposed under 

21 such section shall be reduced by an amount 

22 which bears the same ratio to such amount (de23 termined without regard to this subsection) 

24 as— 


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1 ‘‘(i) the number of days in the cal2 endar year after the date of the individ3 ual’s death, bears to 

4 ‘‘(ii) 365. 

5 ‘‘(2) COORDINATION WITH ESTATE TAX.—For 

6 purposes of section 2053, the tax imposed by this 

7 section for the year of the decedent’s death shall be 

8 considered to have been imposed before such death. 

9 ‘‘(b) APPLICATION TO NON-RESIDENTS.—In the case 

10 of any individual who is a non-resident and not a citizen 

11 of the United States, this subtitle shall apply only to the 

12 property of such individual which is situated in the United 

13 States (determined under rules similar to the rules under 

14 subchapter B of chapter 11). 

15 ‘‘(c) APPLICATION TO COVERED EXPATRIATES.—In 

16 the case of an individual who is a covered expatriate (as 

17 defined in section 877A), section 2901(a) shall be ap18 plied— 

19 ‘‘(1) as if the calendar year ended on the day 

20 before the expatriation, and 

21 ‘‘(2) as if the rate of tax under both subpara22 graphs (A) and (B) of section 2901(b)(1) were 40 

23 percent. 


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1 ‘‘SEC. 2904. INFORMATION REPORTING. 

2 ‘‘(a) IN GENERAL.—Not later than 12 months after 

3 the date of the enactment of this section, the Secretary 

4 shall by regulations require the reporting of any informa5 tion concerning the net value of assets appropriate to en6 force the tax imposed by this chapter. 

7 ‘‘(b) METHOD OF REPORTING.—The Secretary shall, 

8 where appropriate, require the reporting made under sub9 section (a) to be made as a part of existing income report10 ing requirements (including requirements under chapter 

11 4 (relating to taxes to enforce reporting on certain foreign 

12 accounts)). 

13 ‘‘(c) RESPONSIBILITY FOR REPORTING.—The Sec14 retary may impose reporting obligations by reference to 

15 the ownership, control, management, claim to income 

16 from, or other relationship to assets and liabilities for pur17 poses of administering the tax imposed by this section and 

18 may impose such obligations on financial institutions, 

19 business entities, or other persons, including requiring 

20 business entities to provide estimates of the value of the 

21 entity itself. 

22 ‘‘SEC. 2905. ENFORCEMENT. 

23 ‘‘The Secretary shall annually audit not less than 30 

24 percent of taxpayers required to pay the tax imposed 

25 under this chapter.’’. 


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1 (b) NO DEDUCTION FROM INCOME TAXES.—Section 

2 275 of the Internal Revenue Code of 1986 is amended by 

3 inserting after paragraph (6) the following new paragraph: 

4 ‘‘(7) Taxes imposed by chapter 18.’’. 

5 (c) EXTENSION OF TIME FOR PAYMENT OF TAX.— 

6 (1) IN GENERAL.—Section 6161(a) of the In7 ternal Revenue Code of 1986 is amended by adding 

8 at the end the following new paragraph: 

9 ‘‘(3) WEALTH TAX.— 

10 ‘‘(A) IN GENERAL.—In the case of tax11 payer described in subparagraph (B), the Sec12 retary may extend the time for payment of the 

13 tax imposed under chapter 18 for a reasonable 

14 period not to exceed 5 years from the date fixed 

15 for the payment thereof. 

16 ‘‘(B) TAXPAYERS DESCRIBED.—A taxpayer 

17 is described in this subparagraph if such the 

18 Secretary determines— 

19 ‘‘(i) the taxpayer has severe liquidity 

20 constraints, or 

21 ‘‘(ii) immediate payment would cause 

22 undue hardship on an ongoing enter23 prise.’’. 

24 (2) RULES.—Not later than 12 months after 

25 the date of the enactment of this Act, the Secretary 


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1 of the Treasury (or the Secretary’s delegate) shall 

2 establish rules for the application of the amend3 ments made by paragraph (1). 

4 (d) APPLICATION OF ACCURACY RELATED PEN5 ALTIES.— 

6 (1) IN GENERAL.—Section 6662(b) of the In7 ternal Revenue Code of 1986 is amended by adding 

8 at the end the following new paragraph: 

9 ‘‘(10) Any substantial wealth tax valuation un10 derstatement.’’. 

11 (2) SUBSTANTIAL WEALTH TAX UNDERSTATE12 MENT.—Section 6662 of such Code is amended by 

13 adding at the end the following new subsection: 

14 ‘‘(m) APPLICATION TO SUBSTANTIAL WEALTH TAX

15 VALUATION UNDERSTATEMENT.— 

16 ‘‘(1) SUBSTANTIAL WEALTH TAX VALUATION

17 UNDERSTATEMENT DEFINED.— 

18 ‘‘(A) IN GENERAL.—For purposes of this 

19 section, there is a substantial wealth tax valu20 ation understatement if the value of any prop21 erty claimed on any return of tax imposed by 

22 subtitle B–1 is 65 percent or less of the amount 

23 determined to be the correct amount of such 

24 valuation. 


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1 ‘‘(B) LIMITATION.—No penalty shall be 

2 imposed by reason of subsection (b)(10) unless 

3 the portion of the underpayment attributable to 

4 substantial wealth tax valuation understate5 ments for the calendar year exceeds $5,000. 

6 ‘‘(2) INCREASED PENALTY.— 

7 ‘‘(A) IN GENERAL.—In the case of any 

8 portion of an underpayment which is attrib9 utable to one or more substantial wealth tax 

10 valuation understatement, subsection (a) shall 

11 be applied— 

12 ‘‘(i) in the case of a substantial wealth 

13 tax valuation understatement which is a 

14 gross wealth tax valuation misstatement, 

15 by substituting ‘50 percent’ for ‘20 per16 cent’, and 

17 ‘‘(ii) in any other case, by substituting 

18 ‘30 percent’ for ‘20 percent’. 

19 ‘‘(B) GROSS WEALTH TAX VALUATION

20 MISSTATEMENT.—For purposes of subpara21 graph (A), the term ‘gross wealth tax valuation 

22 misstatement’ means a substantial wealth tax 

23 valuation understatement, as determined under 

24 paragraph (1) by substituting ‘40 percent’ for 

25 ‘65 percent’.’’. 


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1 (e) CLERICAL AMENDMENT.—The table of subtitles 

2 of such Code is amended by inserting after the item relat3 ing to subtitle B the following new item: 

‘‘Subtitle B–1—Wealth Tax’’. 

4 (f) EFFECTIVE DATE.—The amendments made by 

5 this section shall apply to calendar years beginning after 

6 December 31, 2024. 

7 (g) PERIODIC REPORTS.—Not later than January 1, 

8 2027, and every 2 years thereafter, the Secretary of the 

9 Treasury (or the Secretary’s delegate) shall submit to 

10 Congress a report on the tax imposed under chapter 18 

11 of the Internal Revenue Code of 1986 (as added by this 

12 Act), including any issues related to the administration 

13 and enforcement of such tax. 

14 SEC. 3. STRENGTHENING DISCLOSURE REQUIREMENTS. 

15 (a) REGULATORY AUTHORITY.—The Secretary of the 

16 Treasury (or the Secretary’s delegate) may issue such 

17 rules and regulations as necessary to prevent taxpayers 

18 from avoiding the purpose of information reporting re19 quirements under the Internal Revenue Code of 1986 by 

20 placing assets in any foreign corporation, partnership, or 

21 trust in which the taxpayer holds directly or indirectly, 

22 a significant interest as the sole or principal owner or the 

23 sole or principal beneficial owner. 

24 (b) FATCA ENFORCEMENT PLAN.—The Secretary 

25 of the Treasury (or the Secretary’s delegate) shall develop 


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1 a comprehensive plan for managing efforts to leverage 

2 data collected under chapter 4 of the Internal Revenue 

3 Code of 1986 in agency compliance efforts. Such plan 

4 shall include an evaluation of the extent to which actions 

5 being undertaken as of the date of the enactment of this 

6 Act for the enforcement of the requirements of such chap7 ter improve voluntary compliance and address noncompli8 ance with such requirements. 

9 SEC. 4. INTERNAL REVENUE SERVICE FUNDING. 

10 (a) IN GENERAL.—Subchapter A of chapter 80 of the 

11 Internal Revenue Code of 1986 is amended by adding at 

12 the end the following new section: 

13 ‘‘SEC. 7813. AUTHORIZATION OF APPROPRIATIONS. 

14 ‘‘There are authorized to be appropriated to the Sec15 retary for the period of fiscal years 2024 through 2034— 

16 ‘‘(1) for enforcement of this title, 

17 $70,000,000,000, 

18 ‘‘(2) for taxpayer services, $10,000,000,000, 

19 and 

20 ‘‘(3) for business system modernization, 

21 $20,000,000,000.’’. 

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

23 for subchapter A of chapter 80 of the Internal Revenue 


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1 Code of 1986 is amended by adding at the end the fol2 lowing new item: 

‘‘Sec. 7813. Authorization of appropriations.’’. 

Æ 


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