SEC. 2. EXCISE TAX ON CERTAIN TAXPAYERS FAILING TO 
SELL EXCESS SINGLE-FAMILY RESIDENCES. 
(a) IN GENERAL.—Subtitle D of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new chapter: 
‘‘CHAPTER 50B—EXCESS SINGLE-FAMILY 
RESIDENCES 
‘‘Sec. 5000E. Excess single-family residences. 
‘‘SEC. 5000E. EXCESS SINGLE-FAMILY RESIDENCES. 
‘‘(a) IN GENERAL.—There is hereby imposed on each 
covered taxpayer for each taxable year a tax in an amount 
equal to the product of— 
‘‘(1) $10,000, and 
‘‘(2) the excess of— 
‘‘(A) the number of single-family resi-
dences owned by the taxpayer as of the last day 
of the taxable year, over 
‘‘(B) 75. 
‘‘(b) COVERED TAXPAYER.—For purposes of this sec-
tion— 
‘‘(1) IN
GENERAL.—The term ‘covered tax-
payer’ means a taxpayer that is not— 
‘‘(A) a mortgage note holder that owns a 
single-family residence through foreclosure, 
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‘‘(B) a organization which is described in 
subsection 501(c)(3) and exempt from tax 
under section 501(a), 
‘‘(C) a person primarily engaged in the 
construction or rehabilitation of single-family 
residences, or 
‘‘(D) a person who owns federally sub-
sidized housing. 
‘‘(2) AGGREGATION RULES.— 
‘‘(A) IN GENERAL.—For purposes of this 
section, all persons which are treated as a sin-
gle employer under subsections (a) and (b) of 
section 52 shall be treated as a single taxpayer. 
‘‘(B) MODIFICATIONS.—For purposes of 
this paragraph— 
‘‘(i) section 52(a) shall be applied by 
substituting 
‘component 
members’ 
for 
‘members’, and 
‘‘(ii) for purposes of applying sub-
section (b), the term ‘trade or business’ 
shall include any activity treated as a trade 
or business under paragraph (5) or (6) of 
subsection (c) (determined without regard 
to the phrase ‘to the extent provided in 
regulations’ in such paragraph (6)). 
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‘‘(C) COMPONENT
MEMBER.—For pur-
poses of this paragraph, the term ‘component 
member’ has the meaning given such term by 
section 1563(b), except that the determination 
shall be made without regard to subsection 
(b)(2). 
‘‘(c) OTHER RULES AND DEFINITIONS.—For pur-
poses of this section: 
‘‘(1) SINGLE-FAMILY
RESIDENCE.—The term 
‘single-family residence’ means a residential property 
consisting not more than 4 dwelling units. 
‘‘(2) OWN.— 
‘‘(A) IN GENERAL.—The term ‘own’, with 
respect to a single-family residence, means hav-
ing a direct majority ownership interest in the 
single-family residence. 
‘‘(B) 
SPECIAL
RULE
FOR
CERTAIN 
SALES.— 
‘‘(i) IN
GENERAL.—Notwithstanding 
subparagraph (A), for purposes of sub-
sections (a)(2)(A), any single-family resi-
dence which is owned by a covered tax-
payer as of the first day of the taxable 
year and which is sold or transferred dur-
ing such taxable year by the covered tax-
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payer in a sale or transfer described in 
clause (ii) shall be treated as a single-fam-
ily residence which is owned by the covered 
taxpayer as of the last day of such taxable 
year. 
‘‘(ii) SALES
DESCRIBED.—A sale or 
transfer is described in this clause if such 
sale or transfer is a sale or transfer to— 
‘‘(I) a corporation or entity en-
gaged in a trade or business, 
‘‘(II) a group of more than 2 in-
dividuals, or 
‘‘(III) a person who owns any 
other single-family residence at the 
time of such sale. 
‘‘(d) REPORTING.— 
‘‘(1) IN GENERAL.—The Secretary shall require 
such reporting as the Secretary determines nec-
essary or appropriate to carry out the purposes of 
this section, including requiring a certification of the 
following from each purchaser or transferee of a sin-
gle-family residence: 
‘‘(A) The name and address of the pur-
chaser or transferee. 
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‘‘(B) Identify whether the sale is a sale de-
scribed in subsection (c)(2)(B)(ii) of the Inter-
nal Revenue Code 1986. 
‘‘(2) FAILURE TO REPORT.— 
‘‘(A) IN GENERAL.—Any person who fails 
to report information required under paragraph 
(1) or who fails to include correct information 
in such report shall pay a penalty of $50,000. 
‘‘(B) REASONABLE
CAUSE
WAIVER.—No 
penalty shall be imposed under this paragraph 
with respect to any failure if it is shown that 
such failure is due to reasonable cause and not 
to willful neglect. 
‘‘(C) TREATMENT OF PENALTY.—The pen-
alty under this paragraph shall be paid upon 
notice and demand by the Secretary, and shall 
be assessed and collected in the same manner 
as an assessable penalty under subchapter B of 
chapter 68.’’. 
(b) CLERICAL AMENDMENT.—The table of chapters 
for subtitle D of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new item: 
‘‘CHAPTER 50B—EXCESS SINGLE-FAMILY RESIDENCES’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2025. 
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SEC. 3. USE OF TAX REVENUES FOR DOWN PAYMENT AS-
SISTANCE GRANTS. 
(a) ESTABLISHMENT OF HOUSING TRUST FUND.— 
(1) 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. HOUSING 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 Housing Trust Fund (hereinafter in 
this section referred to as the ‘Trust Fund’), consisting 
of such amounts as may be appropriated or credited to 
such Trust Fund as provided in this section and section 
9602(b). 
‘‘(b) TRANSFERS TO TRUST FUND.—There are here-
by appropriated to the Housing Trust Fund amounts 
equivalent to revenues received in the Treasury from the 
tax imposed by section 5000E. 
‘‘(c) EXPENDITURES FROM TRUST FUND.—Amounts 
in the Housing Trust Fund shall be available, as provided 
in appropriations Acts, only for grants under section 3(b) 
of the American Neighborhoods Protection Act of 2025.’’. 
(2) CLERICAL AMENDMENT.—The table of sec-
tions for subchapter A of chapter 98 of the Internal 
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Revenue Code of 1986 is amended by adding at the 
end the following new item: 
‘‘Sec. 9512. Housing Trust Fund.’’. 
(b) GRANTS PROGRAM FOR DOWN PAYMENT ASSIST-
ANCE PROGRAMS.— 
(1) ESTABLISHMENT.—The Secretary of Hous-
ing and Urban Development shall establish a pro-
gram under which the Secretary makes grants to 
State housing finance agencies to establish new or 
supplement existing programs that provide down 
payment assistance to families purchasing homes 
within the State. 
(2) PRIORITY.—A State housing finance agency 
that receives a grant under this section shall give 
priority to families seeking assistance to purchase 
any single-family residence that is sold or trans-
ferred by a covered taxpayer (as defined in section 
5000E(b) of the Internal Revenue Code of 1986, as 
added by section 2). 
Æ 
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