I 

118TH CONGRESS 

1ST SESSION H. R. 6416 

To amend the Internal Revenue Code of 1986 to impose certain tax penalties 

in connection with the invasion of Ukraine. 

IN THE HOUSE OF REPRESENTATIVES 

NOVEMBER 15, 2023 

Mr. DOGGETT (for himself, Mr. WILSON of South Carolina, Mr. BACON, Mr. 

FITZPATRICK, Mrs. RADEWAGEN, Ms. SALAZAR, Mr. SMITH of New Jersey, Mr. BLUMENAUER, Mr. BOYLE of Pennsylvania, Ms. CHU, Mr. 

CLEAVER, Mr. COHEN, Mr. COSTA, Mr. CUELLAR, Mr. DAVIS of Illinois, 

Mr. GARAMENDI, Mr. GOLDMAN of New York, Mr. GOTTHEIMER, Mr. 

GREEN of Texas, Mr. GRIJALVA, Mr. JOHNSON of Georgia, Ms. KAPTUR, 

Mr. KEATING, Mr. KHANNA, Mr. KILDEE, Mr. LANDSMAN, Mr. LIEU, 

Mr. LYNCH, Mr. MAGAZINER, Mr. MCGOVERN, Mr. MEEKS, Mr. 

MORELLE, Ms. NORTON, Mr. PALLONE, Mr. PANETTA, Mr. PASCRELL, 

Mr. PAYNE, Mr. RUPPERSBERGER, Ms. SCHAKOWSKY, Mr. SCHIFF, Mr. 

SCHNEIDER, Mr. SHERMAN, Mr. SWALWELL, Ms. TITUS, Mr. TRONE, 

Mr. VARGAS, Mr. QUIGLEY, Mr. LAMBORN, Ms. STEVENS, Ms. MENG, 

Mr. NADLER, and Mr. TONKO) introduced the following bill; which was 

referred to the Committee on Foreign Affairs, and in addition to the 

Committee on Ways and Means, 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 impose 

certain tax penalties in connection with the invasion of 

Ukraine. 

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 ‘‘Russian War Crimes 

3 in Ukraine Tax Act’’. 

4 SEC. 2. TAXATION OF INCOME ON FROZEN ASSETS OF RUS5 SIA AND BELARUS. 

6 (a) IN GENERAL.—Subpart D of part II of sub7 chapter N of chapter 1 of the Internal Revenue Code of 

8 1986 is amended by inserting after section 892 the fol9 lowing new section: 

10 ‘‘SEC. 892A. TAXATION OF INCOME ON FROZEN ASSETS OF 

11 RUSSIA AND BELARUS. 

12 ‘‘(a) IN GENERAL.—Notwithstanding sections 892 

13 and 895 (or any other provision of law), there is hereby 

14 imposed for each taxable year on the disqualified income 

15 of any specified foreign government a tax equal to 100 

16 percent thereof. 

17 ‘‘(b) WITHHOLDING.— 

18 ‘‘(1) IN GENERAL.—Notwithstanding section 

19 203 of the International Emergency Economic Pow20 ers Act (or any other provision of law), any person 

21 having control, receipt, custody, disposal, or pay22 ment of disqualified income with respect to which 

23 tax is imposed under subsection (a) shall deduct and 

24 withhold from such income a tax equal to 100 per25 cent thereof. 


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1 ‘‘(2) APPLICATION OF CERTAIN RULES.—For 

2 purposes of subchapter B of chapter 3, section 33, 

3 and such other provisions as the Secretary may pro4 vide, paragraph (1) shall be treated as part of sub5 chapter A of chapter 3. 

6 ‘‘(c) DISQUALIFIED INCOME.—For purposes of this 

7 section, the term ‘disqualified income’ means any interest 

8 or dividends payable with respect to assets which are 

9 blocked using the authorities provided by section 203 of 

10 the International Emergency Economic Powers Act. 

11 ‘‘(d) SPECIFIED FOREIGN GOVERNMENT.—For pur12 poses of this section, the term ‘specified foreign govern13 ment’ means the foreign governments (within the meaning 

14 of section 892 and the regulations issued thereunder) of 

15 Russia and Belarus.’’. 

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

17 for subpart D of part II of subchapter N of chapter 1 

18 of such Code is amended by inserting after the item relat19 ing to section 892 the following new item: 

‘‘Sec. 892A. Taxation of income on frozen assets of Russia and Belarus.’’. 

20 (c) OVERRIDE OF TREATY OBLIGATIONS.—Notwith21 standing any other provision of law, this section (and the 

22 amendments made by this section) shall apply without re23 gard to any treaty obligation of the United States. 


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

2 this section shall apply to interest and dividends received 

3 after the date of the enactment of this Act. 

4 SEC. 3. ESTABLISHMENT OF UKRAINE RECONSTRUCTION 

5 TRUST FUND. 

6 (a) IN GENERAL.—Subchapter A of chapter 98 of the 

7 Internal Revenue Code of 1986 is amended by adding at 

8 the end the following new section: 

9 ‘‘SEC. 9512. UKRAINE RECONSTRUCTION TRUST FUND. 

10 ‘‘(a) CREATION OF TRUST FUND.—There is estab11 lished in the Treasury of the United States a trust fund 

12 to be known as the ‘Ukraine Reconstruction Trust Fund’, 

13 consisting of such amounts as may be appropriated to 

14 such fund as provided in this section. 

15 ‘‘(b) TRANSFERS TO TRUST FUND.—There are here16 by appropriated to the Ukraine Reconstruction Trust 

17 Fund amounts equivalent to the net revenues received in 

18 the Treasury from the taxes imposed under section 892A. 

19 ‘‘(c) EXPENDITURES FROM TRUST FUND.—Amounts 

20 in the Ukraine Reconstruction Trust Fund shall be avail21 able, as provided in appropriations Acts, only to the Sec22 retary of State for purposes of— 

23 ‘‘(1) reconstruction and rebuilding efforts in 

24 Ukraine, 


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1 ‘‘(2) humanitarian assistance to the people of 

2 Ukraine, 

3 ‘‘(3) fostering long-term economic growth and 

4 private sector development in Ukraine, and 

5 ‘‘(4) bolstering transparent and accountable 

6 governance of the Ukrainian economy. 

7 ‘‘(d) TRUST FUND NOT INTEREST-BEARING.—Sec8 tion 9602(b) shall not apply to the Ukraine Reconstruc9 tion Trust Fund. 

10 ‘‘(e) REQUIREMENTS UNDER FOREIGN ASSISTANCE

11 ACT OF 1961.—Any assistance made available from 

12 amounts in the Ukraine Reconstruction Trust Fund shall 

13 be subject to all applicable requirements for the provision 

14 of such assistance for the same or similar purpose author15 ized by the Foreign Assistance Act of 1961 (22 U.S.C. 

16 2151 et seq.), including requirements under such Act re17 lating to administrative authorities, congressional notifica18 tions, and reporting.’’. 

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

20 for subchapter A of chapter 98 of such Code is amended 

21 by adding at the end the following new item: 

‘‘Sec. 9512. Ukraine Reconstruction Trust Fund.’’. 

22 (c) REPORT.— 

23 (1) IN GENERAL.—Not later than 1 year after 

24 the date of the enactment of this Act, and annually 

25 thereafter for 3 years, the Secretary of State shall 


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1 submit to the appropriate congressional committees 

2 a report detailing the use of any funds made avail3 able from the Ukrainian Reconstruction Trust Fund. 

4 (2) APPROPRIATE CONGRESSIONAL COMMIT5 TEES.—In this subsection, the term ‘‘appropriate 

6 congressional committees’’ means— 

7 (A) the Committee on Foreign Affairs, the 

8 Committee on Ways and Means, and the Com9 mittee on Appropriations of the House of Rep10 resentatives; and 

11 (B) the Committee on Foreign Relations, 

12 the Committee on Finance, and the Committee 

13 on Appropriations of the Senate. 

14 SEC. 4. DIPLOMATIC ASSISTANCE AUTHORIZATION. 

15 (a) FINDINGS.—Congress makes the following find16 ings: 

17 (1) Since February 24, 2022, Russia has been 

18 engaged an illegal, unjustifiable, and unprovoked 

19 war against Ukraine. 

20 (2) On November 14, 2022, the United Nations 

21 adopted a resolution recognizing that Russia must 

22 bear the international legal consequences for its vio23 lations of international law and Ukrainian sov24 ereignty. 


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1 (3) On December 23, 2022, Congress passed 

2 H.R. 2617, the Consolidated Appropriations Act 

3 2023, which was signed by the President of the 

4 United States on December 29, 2022, and author5 ized the United States Government to transfer the 

6 illegally begotten assets of Russian oligarchs to 

7 Ukraine. 

8 (4) In October 2023, nearly $300,000,000,000 

9 of Russian sovereign assets are frozen in countries 

10 around the world but less than 2 percent of those 

11 funds are in held in the United States. 

12 (5) The transfer of a 3 percent capital gain on 

13 the Russian sovereign assets frozen around the 

14 world would exceed a transfer of 100 percent of all 

15 of the Russian sovereign assets currently within the 

16 United States. 

17 (b) STATEMENT OF POLICY.—It is the policy of the 

18 United States that: 

19 (1) Any interest or return on Russian sovereign 

20 assets frozen by allies and partners around the world 

21 should be transferred to Ukraine. 

22 (2) The United States should make it a diplo23 matic priority to encourage allies and partners in 

24 Europe, Asia, and around the world to transfer any 

25 return on Russian sovereign assets to Ukraine. 


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1 (c) AUTHORIZATION OF APPROPRIATIONS.—There is 

2 authorized to be appropriated $25,000,000 for the United 

3 States Special Representative for Ukraine’s Economic Re4 covery to advance the policies set forth in subsection (b). 

5 SEC. 5. SUPPORT AT THE UNITED NATIONS. 

6 (a) IN GENERAL.—The Secretary of State shall di7 rect the United States Permanent Representative to the 

8 United Nations to use the voice, vote, and influence of the 

9 United States to encourage other countries to develop 

10 mechanisms to transfer any capital gains on Russian sov11 ereign assets to Ukraine. 

12 (b) REPORT.—Not later than one year after the date 

13 of the enactment of this Act, the Secretary of State shall 

14 submit a report to the Committee on Foreign Affairs of 

15 the House of Representatives and the Committee on For16 eign Relations of the Senate a report detailing efforts and 

17 actions of the Permanent Representative as directed by 

18 subsection (a). 

Æ 


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