II 

118TH CONGRESS 

2D SESSION S. 3673 

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

purchase of single-family homes by certain large investors, and for other 

purposes. 

IN THE SENATE OF THE UNITED STATES 

JANUARY 25, 2024 

Mr. REED (for himself, Ms. SMITH, Mrs. GILLIBRAND, Mr. BLUMENTHAL, 

Ms. KLOBUCHAR, Mr. FETTERMAN, and Ms. BALDWIN) introduced the 

following bill; which was read twice and referred to the Committee on Finance 

A BILL 

To amend the Internal Revenue Code of 1986 to impose 

a tax on the purchase of single-family homes by certain 

large investors, 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 ‘‘Affordable Housing 

5 and Homeownership Protection Act of 2024’’. 


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•S 3673 IS

1 SEC. 2. TAX ON CERTAIN INVESTOR PURCHASES OF SIN2 GLE-FAMILY HOMES. 

3 (a) IN GENERAL.—Chapter 36 of the Internal Rev4 enue Code of 1986 is amended by adding at the end the 

5 following new subchapter: 

6 ‘‘Subchapter G—Certain Home Purchases 

7 ‘‘SEC. 4499. TAX ON CERTAIN INVESTOR PURCHASES OF 

8 SINGLE-FAMILY HOMES. 

9 ‘‘(a) IN GENERAL.—There is hereby imposed on each 

10 covered investor a tax equal to the applicable percentage 

11 of the purchase price paid by such covered investor with 

12 respect to any covered home purchase during the taxable 

13 year. 

14 ‘‘(b) APPLICABLE PERCENTAGE.—For purposes of 

15 subsection (a), the applicable percentage is— 

16 ‘‘(1) 1 percent in the case of a medium-sized in17 vestor, 

18 ‘‘(2) 3 percent in the case of a large investor, 

19 and 

20 ‘‘(3) 5 percent in the case of a giant investor. 

21 ‘‘(c) COVERED INVESTOR.—For purposes of this sec22 tion— 

23 ‘‘(1) IN GENERAL.—The term ‘covered investor’ 

24 means any person, other than a person described in 

25 paragraph (6), who is a medium-sized investor, large 

26 investor, or giant investor. 


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•S 3673 IS

1 ‘‘(2) MEDIUM-SIZED INVESTOR.—The term ‘me2 dium-sized investor’ means any person who owns 

3 more than 15 and not more than 25 single-family 

4 homes as of the last day of the taxable year. 

5 ‘‘(3) LARGE INVESTOR.—The term ‘large inves6 tor’ means any person who owns more than 25 and 

7 not more than 100 single-family homes as of the last 

8 day of the taxable year. 

9 ‘‘(4) GIANT INVESTOR.—The term ‘giant inves10 tor’ means any person who owns more than 100 sin11 gle-family homes as of the last day of the taxable 

12 year. 

13 ‘‘(5) NEW CONSTRUCTION EXCLUDED.—Any 

14 new single-family home which is constructed by the 

15 taxpayer shall not be taken into account for pur16 poses of this subsection, unless such single-family 

17 home replaces a previous single-family home on the 

18 same site which was purchased by the taxpayer and 

19 replaced with the newly constructed single-family 

20 home. 

21 ‘‘(6) EXCEPTIONS.—A person described in this 

22 paragraph is— 

23 ‘‘(A) any organization which is exempt 

24 from taxation under section 501(a), the pri25 mary purpose of which is related to affordable 


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•S 3673 IS

1 housing, housing counseling, or neighborhood 

2 stabilization, 

3 ‘‘(B) any State or political subdivision 

4 thereof, 

5 ‘‘(C) any public housing authority or its in6 strumentalities, 

7 ‘‘(D) any land bank, or 

8 ‘‘(E) any community land trust. 

9 ‘‘(d) TERMS RELATING TO HOME PURCHASE, ETC.— 

10 For purposes of this section— 

11 ‘‘(1) COVERED HOME PURCHASE.— 

12 ‘‘(A) IN GENERAL.—The term ‘covered 

13 home purchase’ means the purchase of a single14 family home by a covered investor. 

15 ‘‘(B) NEW CONSTRUCTION.—The construc16 tion of a new single-family home by the tax17 payer shall not be treated as a purchase, unless 

18 such new single-family home is taken into ac19 count for purposes of subsection (c) by reason 

20 of paragraph (5) thereof. 

21 ‘‘(2) PURCHASE PRICE.—The term ‘purchase 

22 price’ means the total amount paid, including the 

23 amount of any indebtedness incurred or assumed, by 

24 the taxpayer to acquire a single-family home from 

25 the seller. 


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•S 3673 IS

1 ‘‘(3) SINGLE-FAMILY HOME.—The term ‘single2 family home’ has the meaning given such term by 

3 section 81.2 of title 24, Code of Federal Regula4 tions. 

5 ‘‘(4) OWN.—The term ‘own’ means directly or 

6 indirectly possessing a majority interest in a single7 family home. 

8 ‘‘(e) AGGREGATION RULES.— 

9 ‘‘(1) IN GENERAL.—Except as otherwise pro10 vided in paragraph (2), all persons treated as a sin11 gle employer under subsection (a) or (b) of section 

12 52, or subsection (m) or (o) of section 414, shall be 

13 treated as 1 person for purposes of this section. 

14 ‘‘(2) MODIFICATIONS.—For purposes of this 

15 subsection— 

16 ‘‘(A) section 52(a) shall be applied by sub17 stituting ‘component members’ for ‘members’, 

18 and 

19 ‘‘(B) for purposes of applying section 

20 52(b), the term ‘trade or business’ shall include 

21 any activity treated as a trade or business 

22 under paragraph (5) or (6) of section 469(c) 

23 (determined without regard to the phrase ‘To 

24 the extent provided in regulations’ in such para25 graph (6)). 


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•S 3673 IS

1 ‘‘(3) COMPONENT MEMBER.—For purposes of 

2 paragraph (2), the term ‘component member’ has 

3 the meaning given such term by section 1563(b), de4 termined without regard to paragraph (2) thereof. 

5 ‘‘(f) REPORTING.—Each person who is a covered in6 vestor for the taxable year shall attach to the return of 

7 the tax imposed by this section a report containing infor8 mation, in such form as the Secretary shall prescribe, 

9 on— 

10 ‘‘(1) the number of single-family homes owned 

11 on the last day of the taxable year by such person, 

12 and 

13 ‘‘(2) the number of single-family homes pur14 chased by such person during the taxable year.’’. 

15 (b) CLERICAL AMENDMENT.—The table of sub16 chapters for chapter 36 of the Internal Revenue Code of 

17 1986 is amended by adding at the end the following new 

18 item: 

‘‘SUBCHAPTER G—CERTAIN HOME PURCHASES’’. 

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

20 this section shall apply to taxable years beginning after 

21 December 31, 2023. 

22 SEC. 3. REVENUES. 

23 The Secretary of the Treasury shall allocate or other24 wise transfer such revenues resulting from the tax imVerDate Sep 11 2014 05:04 Jan 30, 2024 Jkt 049200 PO 00000 Frm 00006 Fmt 6652 Sfmt 6201 E:\BILLS\S3673.IS S3673

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•S 3673 IS

1 posed by section 4499 of the Internal Revenue Code of 

2 1986 as follows: 

3 (1) 65 percent of such amounts to the Sec4 retary of Housing and Urban Development to pro5 vide additional funding for the Housing Trust Fund 

6 established under section 1338(a) of the Federal 

7 Housing Enterprises Financial Safety and Sound8 ness Act of 1992 (12 U.S.C. 4568(a)). 

9 (2) 35 percent of such amounts to provide addi10 tional funding for the Capital Magnet Fund estab11 lished under section 1339(a) of the Federal Housing 

12 Enterprises Financial Safety and Soundness Act of 

13 1992 (12 U.S.C. 4569(a)). 

14 SEC. 4. HOUSING TRUST FUND SMALL STATE MINIMUM. 

15 Section 1338(c)(4)(C) of the Federal Housing Enter16 prises Financial Safety and Soundness Act of 1992 (12 

17 U.S.C. 4568(c)(4)(C)) is amended by striking 

18 ‘‘$3,000,000’’ each place that term appears and inserting 

19 ‘‘$7,000,000’’. 

Æ 


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