I 

118TH CONGRESS 

1ST SESSION H. R. 4919 

To amend the Internal Revenue Code of 1986 to establish a wealth tax, 

and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

JULY 26, 2023 

Ms. LEE of California (for herself, Ms. LEE of Pennsylvania, Ms. TLAIB, Mr. 

BOWMAN, Mr. GARCI ́A of Illinois, Mr. GRIJALVA, Mr. NADLER, Ms. 

OMAR, Mr. HUFFMAN, Mrs. WATSON COLEMAN, and Mr. RASKIN) 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 establish 

a wealth tax, 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 ‘‘Oligarch Act of 2023’’. 

5 SEC. 2. IMPOSITION OF WEALTH TAX. 

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

7 1986 is amended by inserting after subtitle B the fol8 lowing new subtitle: 


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1 ‘‘Subtitle B–1—Wealth Tax 

‘‘CHAPTER 18—DETERMINATION OF WEALTH TAX

2 ‘‘CHAPTER 18—DETERMINATION OF 

3 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. 

4 ‘‘SEC. 2901. IMPOSITION OF TAX. 

5 ‘‘(a) IN GENERAL.—In the case of any applicable tax6 payer, a tax is hereby imposed on the net value of all tax7 able assets of the taxpayer on the last day of any calendar 

8 year. 

9 ‘‘(b) COMPUTATION OF TAX.— 

10 ‘‘(1) INDIVIDUALS.—In the case of an indi11 vidual, the tax imposed by this section shall be equal 

12 to the sum of— 

13 ‘‘(A) 2 percent of so much of the net value 

14 of all taxable assets of the taxpayer as exceed 

15 the threshold amount but do not exceed the 

16 product of 10 multiplied by threshold amount, 

17 ‘‘(B) 4 percent of so much of the net value 

18 of all taxable assets of the taxpayer as exceed 

19 the product of 10 multiplied by the threshold 

20 amount but do not exceed the product of 100 

21 multiplied by the threshold amount, 


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1 ‘‘(C) 6 percent of so much of the net value 

2 of all taxable assets of the taxpayer as exceed 

3 the product of 100 multiplied by the threshold 

4 amount but do not exceed the product of 1,000 

5 multiplied by the threshold amount, plus 

6 ‘‘(D) 8 percent of so much of the net value 

7 of all taxable assets of the taxpayer as exceed 

8 the product of 1,000 multiplied by the threshold 

9 amount. 

10 ‘‘(2) TRUSTS.—In the case of a trust, the tax 

11 imposed by this section shall be equal to 8 percent 

12 of so much of the net value of all taxable assets of 

13 the taxpayer as exceed the threshold amount. 

14 ‘‘(c) APPLICABLE TAXPAYER.— 

15 ‘‘(1) IN GENERAL.—The term ‘applicable tax16 payer’ means any individual or any trust (other than 

17 a trust described in section 401(a) and exempt from 

18 tax under section 501(a)). 

19 ‘‘(2) TREATMENT OF MARRIED INDIVIDUALS.— 

20 For purposes of this section, individuals who are 

21 married (as defined in section 7703) shall be treated 

22 as one applicable taxpayer. 

23 ‘‘(d) THRESHOLD AMOUNT.—For purposes of this 

24 section, the term ‘threshold amount’ means the amount 

25 that is the product of 1,000 multiplied by the greater of— 


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1 ‘‘(1) $50,000, or 

2 ‘‘(2) the applicable median house hold wealth. 

3 ‘‘(e) APPLICABLE MEDIAN HOUSEHOLD WEALTH.— 

4 The Secretary shall annually determine the median house5 hold wealth with respect to the United States for purposes 

6 of this section. 

7 ‘‘(f) APPLICATION TO TRUSTS.— 

8 ‘‘(1) ATTRIBUTION OF ASSETS IN TRUST.—In 

9 determining the assets of a taxpayer for purposes of 

10 subsection (a): 

11 ‘‘(A) GRANTOR TRUST.—In the case of a 

12 grantor trust, the grantor shall be treated as 

13 holding all the assets of the trust. 

14 ‘‘(B) BENEFICIARY TRUST.—In the case of 

15 a beneficiary trust, each beneficiary of the trust 

16 shall be treated as holding a fraction of the as17 sets of the trust in proportion to such bene18 ficiary’s interest in such trust. 

19 ‘‘(2) PROPERTY OF TRUSTS.—Any asset treated 

20 as held by a grantor or beneficiary under paragraph 

21 (1) shall not be treated as held by the trust for pur22 poses of this section. 

23 ‘‘(3) TRUSTS RELATING TO COMMON BENE24 FICIARIES.—Trusts benefitting substantially the 


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1 same beneficiaries shall be treated as a single appli2 cable taxpayer for purposes of this section. 

3 ‘‘(4) DEFINITIONS.—For purposes of this sec4 tion: 

5 ‘‘(A) GRANTOR TRUST.—The term ‘grantor 

6 trust’ means a trust in which a taxpayer is 

7 treated as owning an asset of the trust under 

8 subpart E of part I of subchapter J of chapter 

9 1. 

10 ‘‘(B) BENEFICIARY TRUST.—The term 

11 ‘beneficiary trust’ means any trust that is not 

12 a grantor trust. 

13 ‘‘(g) REGULATIONS.—The Secretary shall issue such 

14 regulations or other guidance as may be necessary or ap15 propriate to carry out the purposes of this section, includ16 ing— 

17 ‘‘(1) regulations establishing a process by which 

18 a beneficiary may demonstrate the portion of such 

19 beneficiary’s interest in a trust, and 

20 ‘‘(2) regulations for determining the appro21 priate attribution of assets in a trust for purposes 

22 of subsection (e)(1) in the case of a trust with mul23 tiple grantors. 


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

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

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

4 the excess of— 

5 ‘‘(1) the value of all property of the taxpayer 

6 (other than property excluded under subsection (b)), 

7 real or personal, tangible or intangible, wherever sit8 uated, over 

9 ‘‘(2) any debts (including any debts secured by 

10 property excluded under subsection (b)) owed by the 

11 taxpayer. 

12 ‘‘(b) EXCLUSION FOR CERTAIN ASSETS UNDER

13 $50,000.—Property of the taxpayer shall not be taken 

14 into account under subsection (a) if such property— 

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

16 without regard to any debt owed by the taxpayer 

17 with respect to such property), 

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

19 ‘‘(3) is not property— 

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

21 of the taxpayer, 

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

23 is allowable under section 212, or 

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

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

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


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1 asset that maintains or increases its value over 

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

3 Revenue Procedure 2018–08). 

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

5 TAXPAYER.—For purposes of this subtitle: 

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

7 property that would be included in the estate of the 

8 taxpayer if the taxpayer died shall be treated as 

9 property of the taxpayer. 

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

11 property transferred by the taxpayer after the date 

12 of the enactment of this chapter, to an individual 

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

14 determined under section 267(c)(4)) and has not at15 tained the age of 18 shall be treated as property of 

16 the taxpayer for any calendar year before the year 

17 in which such individual attains the age of 18. 

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

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

20 this section, the Secretary shall establish rules and meth21 ods for determining the value of any asset for purposes 

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

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

24 ascertainable value. Such rules and methods— 


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1 ‘‘(1) may utilize retrospective and prospective 

2 formulaic valuation methods not currently in use by 

3 the Secretary, 

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

5 approaches for designated assets, including 

6 formulaic approaches based on proxies for deter7 mining presumptive valuations, formulaic approaches 

8 based on prospective adjustments from purchase 

9 prices or other prior events, or formulaic approaches 

10 based on retrospectively adding deferral charges 

11 based on eventual sale prices or other specified later 

12 events indicative of valuation, and 

13 ‘‘(3) may address the use of valuation dis14 counts. 

15 ‘‘SEC. 2903. SPECIAL RULES. 

16 ‘‘(a) DECEASED INDIVIDUALS.— 

17 ‘‘(1) IN GENERAL.—In the case of any indi18 vidual who dies during a calendar year and who is 

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

20 ‘‘(A) section 2901 shall be applied by sub21 stituting ‘the date of the applicable taxpayer’s 

22 death’ for ‘the last day of any calendar year’, 

23 and 

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

25 such section shall be reduced by an amount 


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1 which bears the same ratio to such amount (de2 termined without regard to this subsection) 

3 as— 

4 ‘‘(i) the number of days in the cal5 endar year after the date of the individ6 ual’s death, bears to 

7 ‘‘(ii) 365. 

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

9 purposes of section 2053, the tax imposed by this 

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

11 considered to have been imposed before such death. 

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

13 of any nonresident alien individual, this subtitle shall 

14 apply only to the property of such individual which is situ15 ated in the United States (determined under rules similar 

16 to the rules under subchapter B of chapter 11). 

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

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

19 defined in section 877A), section 2901(a) shall be applied 

20 as if the calendar year ended on the day before the expa21 triation. 

22 ‘‘SEC. 2904. INFORMATION REPORTING. 

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

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

25 shall by regulation require the reporting of any informaVerDate Sep 11 2014 01:21 Aug 17, 2023 Jkt 039200 PO 00000 Frm 00009 Fmt 6652 Sfmt 6201 E:\BILLS\H4919.IH H4919

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1 tion concerning the net value of assets appropriate to en2 force the tax imposed by this chapter. 

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

4 where appropriate, require the reporting made under sub5 section (a) to be made as a part of existing income report6 ing requirements (including requirements under chapter 

7 4 (relating to taxes to enforce reporting on certain foreign 

8 accounts)). 

9 ‘‘(c) RESPONSIBILITY FOR REPORTING.—The Sec10 retary may impose reporting obligations by reference to 

11 the ownership, control, management, claim to income 

12 from, or other relationship to assets and liabilities for pur13 poses of administering the tax imposed by this section and 

14 may impose such obligations on financial institutions, 

15 business entities, or other persons, including requiring 

16 business entities to provide estimates of the value of the 

17 entity itself. 

18 ‘‘SEC. 2905. ENFORCEMENT. 

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

20 percent of taxpayers required to pay the tax imposed 

21 under this chapter.’’. 

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

23 275 of such Code is amended by inserting after paragraph 

24 (6) the following new paragraph: 

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


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

2 (1) IN GENERAL.—Section 6161(a) of such 

3 Code is amended by adding at the end the following 

4 new paragraph: 

5 ‘‘(3) WEALTH TAX.— 

6 ‘‘(A) IN GENERAL.—In the case of an ap7 plicable taxpayer described in subparagraph 

8 (B), the Secretary may extend the time for pay9 ment of the tax imposed under chapter 18 for 

10 a reasonable period not to exceed 5 years from 

11 the date fixed for the payment thereof. 

12 ‘‘(B) TAXPAYERS DESCRIBED.—An appli13 cable taxpayer is described in this subparagraph 

14 if such the Secretary determines— 

15 ‘‘(i) the applicable taxpayer has severe 

16 liquidity constraints, or 

17 ‘‘(ii) immediate payment would cause 

18 undue hardship on an ongoing enterprise. 

19 ‘‘(C) APPLICABLE TAXPAYER.—For pur20 poses of this paragraph, the term ‘applicable 

21 taxpayer’ has the meaning given such term in 

22 section 2901.’’. 

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

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

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


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1 establish rules for the application of the amend2 ments made by paragraph (1). 

3 (d) APPLICATION OF ACCURACY RELATED PEN4 ALTIES.— 

5 (1) IN GENERAL.—Section 6662(b) of such 

6 Code is amended by adding at the end the following 

7 new paragraph: 

8 ‘‘(10) Any substantial wealth tax valuation un9 derstatement.’’. 

10 (2) SUBSTANTIAL WEALTH TAX UNDERSTATE11 MENT.—Section 6662 of such Code is amended by 

12 adding at the end the following new subsection: 

13 ‘‘(m) APPLICATION TO SUBSTANTIAL WEALTH TAX

14 VALUATION UNDERSTATEMENT.— 

15 ‘‘(1) SUBSTANTIAL WEALTH TAX VALUATION

16 UNDERSTATEMENT DEFINED.— 

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

18 section, there is a substantial wealth tax valu19 ation understatement if the value of any prop20 erty claimed on any return of tax imposed by 

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

22 determined to be the correct amount of such 

23 valuation. 

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

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


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1 the portion of the underpayment attributable to 

2 substantial wealth tax valuation understate3 ments for the calendar year exceeds $5,000. 

4 ‘‘(2) INCREASED PENALTY.— 

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

6 portion of an underpayment which is attrib7 utable to one or more substantial wealth tax 

8 valuation understatement, subsection (a) shall 

9 be applied— 

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

11 tax valuation understatement which is a 

12 gross wealth tax valuation misstatement, 

13 by substituting ‘50 percent’ for ‘20 per14 cent’, and 

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

16 ‘30 percent’ for ‘20 percent’. 

17 ‘‘(B) GROSS WEALTH TAX VALUATION

18 MISSTATEMENT.—For purposes of subpara19 graph (A), the term ‘gross wealth tax valuation 

20 misstatement’ means a substantial wealth tax 

21 valuation understatement, as determined under 

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

23 ‘65 percent’.’’. 


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1 (e) EXEMPTION OF TAX EXEMPT ENTITIES.—Sec2 tion 501(a) of such Code is amended by inserting ‘‘and 

3 subtitle B–1’’ after ‘‘this subtitle’’. 

4 (f) CLERICAL AMENDMENT.—The table of subtitles 

5 of such Code is amended by inserting after the item relat6 ing to subtitle B the following new item: 

‘‘Subtitle B–1—Wealth Tax’’. 

7 (g) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to calendar years beginning after 

9 the date of the enactment of this Act. 

Æ 


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