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 Jer-
sey, 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 deter-
mined 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. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00001
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Russian War Crimes 
in Ukraine Tax Act’’. 
SEC. 2. TAXATION OF INCOME ON FROZEN ASSETS OF RUS-
SIA AND BELARUS. 
(a) IN GENERAL.—Subpart D of part II of sub-
chapter N of chapter 1 of the Internal Revenue Code of 
1986 is amended by inserting after section 892 the fol-
lowing new section: 
‘‘SEC. 892A. TAXATION OF INCOME ON FROZEN ASSETS OF 
RUSSIA AND BELARUS. 
‘‘(a) IN GENERAL.—Notwithstanding sections 892 
and 895 (or any other provision of law), there is hereby 
imposed for each taxable year on the disqualified income 
of any specified foreign government a tax equal to 100 
percent thereof. 
‘‘(b) WITHHOLDING.— 
‘‘(1) IN
GENERAL.—Notwithstanding section 
203 of the International Emergency Economic Pow-
ers Act (or any other provision of law), any person 
having control, receipt, custody, disposal, or pay-
ment of disqualified income with respect to which 
tax is imposed under subsection (a) shall deduct and 
withhold from such income a tax equal to 100 per-
cent thereof. 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00002
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
‘‘(2) APPLICATION
OF
CERTAIN
RULES.—For 
purposes of subchapter B of chapter 3, section 33, 
and such other provisions as the Secretary may pro-
vide, paragraph (1) shall be treated as part of sub-
chapter A of chapter 3. 
‘‘(c) DISQUALIFIED INCOME.—For purposes of this 
section, the term ‘disqualified income’ means any interest 
or dividends payable with respect to assets which are 
blocked using the authorities provided by section 203 of 
the International Emergency Economic Powers Act. 
‘‘(d) SPECIFIED FOREIGN GOVERNMENT.—For pur-
poses of this section, the term ‘specified foreign govern-
ment’ means the foreign governments (within the meaning 
of section 892 and the regulations issued thereunder) of 
Russia and Belarus.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for subpart D of part II of subchapter N of chapter 1 
of such Code is amended by inserting after the item relat-
ing to section 892 the following new item: 
‘‘Sec. 892A. Taxation of income on frozen assets of Russia and Belarus.’’. 
(c) OVERRIDE OF TREATY OBLIGATIONS.—Notwith-
standing any other provision of law, this section (and the 
amendments made by this section) shall apply without re-
gard to any treaty obligation of the United States. 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00003
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to interest and dividends received 
after the date of the enactment of this Act. 
SEC. 3. ESTABLISHMENT OF UKRAINE RECONSTRUCTION 
TRUST FUND. 
(a) IN GENERAL.—Subchapter A of chapter 98 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new section: 
‘‘SEC. 9512. UKRAINE RECONSTRUCTION TRUST FUND. 
‘‘(a) CREATION OF TRUST FUND.—There is estab-
lished in the Treasury of the United States a trust fund 
to be known as the ‘Ukraine Reconstruction Trust Fund’, 
consisting of such amounts as may be appropriated to 
such fund as provided in this section. 
‘‘(b) TRANSFERS TO TRUST FUND.—There are here-
by appropriated to the Ukraine Reconstruction Trust 
Fund amounts equivalent to the net revenues received in 
the Treasury from the taxes imposed under section 892A. 
‘‘(c) EXPENDITURES FROM TRUST FUND.—Amounts 
in the Ukraine Reconstruction Trust Fund shall be avail-
able, as provided in appropriations Acts, only to the Sec-
retary of State for purposes of— 
‘‘(1) reconstruction and rebuilding efforts in 
Ukraine, 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00004
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
‘‘(2) humanitarian assistance to the people of 
Ukraine, 
‘‘(3) fostering long-term economic growth and 
private sector development in Ukraine, and 
‘‘(4) bolstering transparent and accountable 
governance of the Ukrainian economy. 
‘‘(d) TRUST FUND NOT INTEREST-BEARING.—Sec-
tion 9602(b) shall not apply to the Ukraine Reconstruc-
tion Trust Fund. 
‘‘(e) REQUIREMENTS UNDER FOREIGN ASSISTANCE 
ACT
OF 1961.—Any assistance made available from 
amounts in the Ukraine Reconstruction Trust Fund shall 
be subject to all applicable requirements for the provision 
of such assistance for the same or similar purpose author-
ized by the Foreign Assistance Act of 1961 (22 U.S.C. 
2151 et seq.), including requirements under such Act re-
lating to administrative authorities, congressional notifica-
tions, and reporting.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for subchapter A of chapter 98 of such Code is amended 
by adding at the end the following new item: 
‘‘Sec. 9512. Ukraine Reconstruction Trust Fund.’’. 
(c) REPORT.— 
(1) IN GENERAL.—Not later than 1 year after 
the date of the enactment of this Act, and annually 
thereafter for 3 years, the Secretary of State shall 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00005
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
submit to the appropriate congressional committees 
a report detailing the use of any funds made avail-
able from the Ukrainian Reconstruction Trust Fund. 
(2) APPROPRIATE
CONGRESSIONAL
COMMIT-
TEES.—In this subsection, the term ‘‘appropriate 
congressional committees’’ means— 
(A) the Committee on Foreign Affairs, the 
Committee on Ways and Means, and the Com-
mittee on Appropriations of the House of Rep-
resentatives; and 
(B) the Committee on Foreign Relations, 
the Committee on Finance, and the Committee 
on Appropriations of the Senate. 
SEC. 4. DIPLOMATIC ASSISTANCE AUTHORIZATION. 
(a) FINDINGS.—Congress makes the following find-
ings: 
(1) Since February 24, 2022, Russia has been 
engaged an illegal, unjustifiable, and unprovoked 
war against Ukraine. 
(2) On November 14, 2022, the United Nations 
adopted a resolution recognizing that Russia must 
bear the international legal consequences for its vio-
lations of international law and Ukrainian sov-
ereignty. 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00006
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
(3) On December 23, 2022, Congress passed 
H.R. 2617, the Consolidated Appropriations Act 
2023, which was signed by the President of the 
United States on December 29, 2022, and author-
ized the United States Government to transfer the 
illegally begotten assets of Russian oligarchs to 
Ukraine. 
(4) In October 2023, nearly $300,000,000,000 
of Russian sovereign assets are frozen in countries 
around the world but less than 2 percent of those 
funds are in held in the United States. 
(5) The transfer of a 3 percent capital gain on 
the Russian sovereign assets frozen around the 
world would exceed a transfer of 100 percent of all 
of the Russian sovereign assets currently within the 
United States. 
(b) STATEMENT OF POLICY.—It is the policy of the 
United States that: 
(1) Any interest or return on Russian sovereign 
assets frozen by allies and partners around the world 
should be transferred to Ukraine. 
(2) The United States should make it a diplo-
matic priority to encourage allies and partners in 
Europe, Asia, and around the world to transfer any 
return on Russian sovereign assets to Ukraine. 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00007
Fmt 6652
Sfmt 6201
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS
(c) AUTHORIZATION OF APPROPRIATIONS.—There is 
authorized to be appropriated $25,000,000 for the United 
States Special Representative for Ukraine’s Economic Re-
covery to advance the policies set forth in subsection (b). 
SEC. 5. SUPPORT AT THE UNITED NATIONS. 
(a) IN GENERAL.—The Secretary of State shall di-
rect the United States Permanent Representative to the 
United Nations to use the voice, vote, and influence of the 
United States to encourage other countries to develop 
mechanisms to transfer any capital gains on Russian sov-
ereign assets to Ukraine. 
(b) REPORT.—Not later than one year after the date 
of the enactment of this Act, the Secretary of State shall 
submit a report to the Committee on Foreign Affairs of 
the House of Representatives and the Committee on For-
eign Relations of the Senate a report detailing efforts and 
actions of the Permanent Representative as directed by 
subsection (a). 
Æ 
VerDate Sep 11 2014 
03:44 Nov 29, 2023
Jkt 049200
PO 00000
Frm 00008
Fmt 6652
Sfmt 6301
E:\BILLS\H6416.IH
H6416
dmwilson on DSKJM0X7X2PROD with BILLS