I 
117TH CONGRESS 
1ST SESSION H. R. 1459 
To amend the Internal Revenue Code of 1986 to impose a tax on the 
net value of assets of a taxpayer, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 1, 2021 
Ms. JAYAPAL (for herself, Mr. BRENDAN F. BOYLE of Pennsylvania, Ms. 
NORTON, Ms. LEE of California, Ms. OMAR, Ms. OCASIO-CORTEZ, Ms. 
BUSH, Mr. TAKANO, Mr. BOWMAN, Ms. SCHAKOWSKY, Mrs. WATSON 
COLEMAN, Mr. GRIJALVA, Mr. JONES, Ms. PRESSLEY, Mr. MCGOVERN, 
Mr. EVANS, Mr. KHANNA, Mr. GARCI´A of Illinois, Ms. CHU, and Mr. 
SMITH of Washington) 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 impose 
a tax on the net value of assets of a taxpayer, and 
for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Ultra-Millionaire Tax 
Act of 2021’’. 
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SEC. 2. IMPOSITION OF WEALTH TAX. 
(a) IN GENERAL.—The Internal Revenue Code of 
1986 is amended by inserting after subtitle B the fol-
lowing new subtitle: 
‘‘Subtitle B–1—Wealth Tax 
‘‘CHAPTER 18—DETERMINATION OF WEALTH TAX 
‘‘CHAPTER 18—DETERMINATION OF 
WEALTH TAX 
‘‘Sec. 2901. Imposition of tax. 
‘‘Sec. 2902. Value of taxable assets. 
‘‘Sec. 2903. Special rules. 
‘‘Sec. 2904. Information reporting. 
‘‘Sec. 2905. Enforcement. 
‘‘SEC. 2901. IMPOSITION OF TAX. 
‘‘(a) IN GENERAL.—In the case of any applicable tax-
payer, a tax is hereby imposed on the net value of all tax-
able assets of the taxpayer on the last day of any calendar 
year. 
‘‘(b) COMPUTATION OF TAX.— 
‘‘(1) IN GENERAL.—The tax imposed by this 
section shall be equal to the sum of— 
‘‘(A) 2 percent of so much of the net value 
of all taxable assets of the taxpayer in excess of 
$50,000,000 
but 
not 
in 
excess 
of 
$1,000,000,000, plus 
‘‘(B) the applicable percentage of so much 
of the net value of all such taxable assets in ex-
cess of $1,000,000,000. 
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No tax shall be imposed under subsection (a) on the 
net value of taxable assets not in excess of 
$50,000,000. 
‘‘(2) APPLICABLE PERCENTAGE.— 
‘‘(A) IN GENERAL.—For purposes of this 
section, the applicable percentage is— 
‘‘(i) except as provided in clause (ii), 
3 percent, and 
‘‘(ii) in the case of any calendar year 
in which there is in effect legislation which 
meets the requirements of subparagraph 
(B), 6 percent. 
‘‘(B) LEGISLATION DESCRIBED.—Legisla-
tion meets the requirements of this paragraph 
if such legislation— 
‘‘(i) establishes a health insurance 
program that provides to all residents of 
the United States comprehensive protec-
tion against the costs of health care and 
health-related services, and 
‘‘(ii) prohibits private entities from 
providing duplicate benefits. 
‘‘(c) APPLICABLE TAXPAYER.— 
‘‘(1) IN GENERAL.—The term ‘applicable tax-
payer’ means any individual or any trust (other than 
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a trust described in section 401(a) and exempt from 
tax under section 501(a)). 
‘‘(2) TREATMENT OF MARRIED INDIVIDUALS.— 
For purposes of this section, individuals who are 
married (as defined in section 7703) shall be treated 
as one applicable taxpayer. 
‘‘(3) TREATMENT OF TRUSTS.— 
‘‘(A) IN GENERAL.—All trusts with sub-
stantially the same beneficiaries shall be treated 
as a single applicable taxpayer. 
‘‘(B) TRANSFERS OF PROPERTY BETWEEN 
TRUSTS.—If a trust transfers property by gift 
or decantation to another trust in any calendar 
year after December 31, 2020, the transferor 
trust and the transferee trust shall be treated 
as a single applicable taxpayer for such cal-
endar year. 
‘‘SEC. 2902. NET VALUE OF TAXABLE ASSETS. 
‘‘(a) IN GENERAL.—For purposes of this subtitle, the 
term ‘net value of all taxable assets’ means, as of any date, 
the value of all property of the taxpayer (other than prop-
erty excluded under subsection (b)), real or personal, tan-
gible or intangible, wherever situated, reduced by any 
debts (including any debts secured by property excluded 
under subsection (b)) owed by the taxpayer. 
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‘‘(b) EXCLUSION
FOR CERTAIN ASSETS UNDER 
$50,000.—Property of the taxpayer shall not be taken 
into account under subsection (a) if such property— 
‘‘(1) has a value of $50,000 or less (determined 
without regard to any debt owed by the taxpayer 
with respect to such property), 
‘‘(2) is tangible personal property, and 
‘‘(3) is not property— 
‘‘(A) which is used in a trade or business 
of the taxpayer, 
‘‘(B) in connection with which a deduction 
is allowable under section 212, or 
‘‘(C) which is a collectible as defined in 
section 408(m), a boat, an aircraft, a mobile 
home, a trailer, a vehicle, or an antique or other 
asset that maintains or increases its value over 
time (within the meaning of section 5.02(2) of 
Revenue Procedure 2018–08). 
‘‘(c) RULES FOR DETERMINING PROPERTY OF THE 
TAXPAYER.—For purposes of this subtitle— 
‘‘(1) PROPERTY
INCLUDED
IN
ESTATE.—Any 
property that would be included in the estate of the 
taxpayer if the taxpayer died shall be treated as 
property of the taxpayer. 
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‘‘(2) PROPERTY OF GRANTOR TRUSTS.—If an 
individual is treated as the owner of any portion of 
a trust under subpart E of subchapter J of chapter 
1, property attributable to such portion of the trust 
shall be treated as property of the individual and not 
as property of the trust. 
‘‘(3) INCLUSION
OF
CERTAIN
GIFTS.—Any 
property transferred by the taxpayer after the date 
of the enactment of this chapter, to an individual 
who is a member of the family of the taxpayer (as 
determined under section 267(c)(4)) and has not at-
tained the age of 18 shall be treated as property of 
the taxpayer for any calendar year before the year 
in which such individual attains the age of 18. 
‘‘(d) ESTABLISHMENT OF VALUATION RULES.—Not 
later than 12 months after the date of the enactment of 
this section, the Secretary shall establish rules and meth-
ods for determining the value of any asset for purposes 
of this subtitle, including rules for the valuation of assets 
that are not publicly traded or that do not have a readily 
ascertainable value. Such rules and methods— 
‘‘(1) may utilize retrospective and prospective 
formulaic valuation methods not currently in use by 
the Secretary, 
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‘‘(2) may require the use of formulaic valuation 
approaches 
for 
designated 
assets, 
including 
formulaic approaches based on proxies for deter-
mining presumptive valuations, formulaic approaches 
based on prospective adjustments from purchase 
prices or other prior events, or formulaic approaches 
based on retrospectively adding deferral charges 
based on eventual sale prices or other specified later 
events indicative of valuation, and 
‘‘(3) may address the use of valuation dis-
counts. 
‘‘SEC. 2903. SPECIAL RULES. 
‘‘(a) DECEASED INDIVIDUALS.— 
‘‘(1) IN GENERAL.—In the case of any indi-
vidual who dies during a calendar year and who is 
not married on the date of such individual’s death— 
‘‘(A) section 2901 shall be applied by sub-
stituting ‘the date of the applicable taxpayer’s 
death’ for ‘the last day of the calendar year’, 
and 
‘‘(B) the amount of the tax imposed under 
such section shall be reduced by an amount 
which bears the same ratio to such amount (de-
termined without regard to this subsection) 
as— 
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‘‘(i) the number of days in the cal-
endar year after the date of the individ-
ual’s death, bears to 
‘‘(ii) 365. 
‘‘(2) COORDINATION WITH ESTATE TAX.—For 
purposes of section 2053, the tax imposed by this 
section for the year of the decedent’s death shall be 
considered to have been imposed before such death. 
‘‘(b) APPLICATION TO NONRESIDENTS.—In the case 
of any individual who is a non-resident and not a citizen 
of the United States, this subtitle shall apply only to the 
property of such individual which is situated in the United 
States (determined under rules similar to the rules under 
subchapter B of chapter 11). 
‘‘(c) APPLICATION TO COVERED EXPATRIATES.—In 
the case of an individual who is a covered expatriate (as 
defined in section 877A), section 2901(a) shall be ap-
plied— 
‘‘(1) as if the calendar year ended on the day 
before the expatriation, and 
‘‘(2) as if the rate of tax under both subpara-
graphs (A) and (B) of section 2901(b)(1) were 40 
percent. 
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‘‘SEC. 2904. INFORMATION REPORTING. 
‘‘(a) IN GENERAL.—Not later than 12 months after 
the date of the enactment of this section, the Secretary 
shall by regulations require the reporting of any informa-
tion concerning the net value of assets appropriate to en-
force the tax imposed by this chapter. 
‘‘(b) METHOD OF REPORTING.—The Secretary shall, 
where appropriate, require the reporting made under sub-
section (a) to be made as a part of existing income report-
ing requirements (including requirements under chapter 
4 (relating to taxes to enforce reporting on certain foreign 
accounts)). 
‘‘(c) RESPONSIBILITY FOR REPORTING.—The Sec-
retary may impose reporting obligations by reference to 
the ownership, control, management, claim to income 
from, or other relationship to assets and liabilities for pur-
poses of administering the tax imposed by this section and 
may impose such obligations on financial institutions, 
business entities, or other persons, including requiring 
business entities to provide estimates of the value of the 
entity itself. 
‘‘SEC. 2905. ENFORCEMENT. 
‘‘The Secretary shall annually audit not less than 30 
percent of taxpayers required to pay the tax imposed 
under this chapter.’’. 
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(b) NO DEDUCTION FROM INCOME TAXES.—Section 
275 of the Internal Revenue Code of 1986 is amended by 
inserting after paragraph (6) the following new paragraph: 
‘‘(7) Taxes imposed by chapter 18.’’. 
(c) EXTENSION OF TIME FOR PAYMENT OF TAX.— 
(1) IN GENERAL.—Section 6161(a) of the In-
ternal Revenue Code of 1986 is amended by adding 
at the end the following new paragraph: 
‘‘(3) WEALTH TAX.— 
‘‘(A) IN GENERAL.—In the case of an ap-
plicable taxpayer described in subparagraph 
(B), the Secretary may extend the time for pay-
ment of the tax imposed under chapter 18 for 
a reasonable period not to exceed 5 years from 
the date fixed for the payment thereof. 
‘‘(B) TAXPAYERS DESCRIBED.—An appli-
cable taxpayer is described in this subparagraph 
if such the Secretary determines— 
‘‘(i) the applicable taxpayer has severe 
liquidity constraints, or 
‘‘(ii) immediate payment would cause 
undue hardship on an ongoing enterprise. 
‘‘(C) APPLICABLE
TAXPAYER.—For pur-
poses of this paragraph, the term ‘applicable 
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taxpayer’ has the meaning given such term 
under section 2901.’’. 
(2) RULES.—Not later than 12 months after 
the date of the enactment of this Act, the Secretary 
of the Treasury (or the Secretary’s delegate) shall 
establish rules for the application of the amend-
ments made by paragraph (1). 
(d) APPLICATION
OF ACCURACY RELATED PEN-
ALTIES.— 
(1) IN GENERAL.—Section 6662(b) of the In-
ternal Revenue Code of 1986 is amended by adding 
at the end the following new paragraph: 
‘‘(10) Any substantial wealth tax valuation un-
derstatement.’’. 
(2) SUBSTANTIAL WEALTH TAX UNDERSTATE-
MENT.—Section 6662 of such Code is amended by 
adding at the end the following new subsection: 
‘‘(m) APPLICATION TO SUBSTANTIAL WEALTH TAX 
VALUATION UNDERSTATEMENT.— 
‘‘(1) SUBSTANTIAL
WEALTH
TAX
VALUATION 
UNDERSTATEMENT DEFINED.— 
‘‘(A) IN GENERAL.—For purposes of this 
section, there is a substantial wealth tax valu-
ation understatement if the value of any prop-
erty claimed on any return of tax imposed by 
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subtitle B–1 is 65 percent or less of the amount 
determined to be the correct amount of such 
valuation. 
‘‘(B) LIMITATION.—No penalty shall be 
imposed by reason of subsection (b)(10) unless 
the portion of the underpayment attributable to 
substantial wealth tax valuation understate-
ments for the calendar year exceeds $5,000. 
‘‘(2) INCREASED PENALTY.— 
‘‘(A) IN
GENERAL.—In the case of any 
portion of an underpayment which is attrib-
utable to one or more substantial wealth tax 
valuation understatement, subsection (a) shall 
be applied— 
‘‘(i) in the case of a substantial wealth 
tax valuation understatement which is a 
gross wealth tax valuation misstatement, 
by substituting ‘50 percent’ for ‘20 per-
cent’, and 
‘‘(ii) in any other case, by substituting 
‘30 percent’ for ‘20 percent’. 
‘‘(B) GROSS
WEALTH
TAX
VALUATION 
MISSTATEMENT.—For purposes of subpara-
graph (A), the term ‘gross wealth tax valuation 
misstatement’ means a substantial wealth tax 
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valuation understatement, as determined under 
paragraph (1) by substituting ‘40 percent’ for 
‘65 percent’.’’. 
(e) CLERICAL AMENDMENT.—The table of subtitles 
of such Code is amended by inserting after the item relat-
ing to subtitle B the following new item: 
‘‘Subtitle B–1—Wealth Tax’’. 
(f) EFFECTIVE DATE.—The amendments made by 
this section shall apply to calendar years beginning after 
December 31, 2022. 
(g) PERIODIC REPORTS.—Not later than January 1, 
2025, and every 2 years thereafter, the Secretary of the 
Treasury (or the Secretary’s delegate) shall submit to 
Congress a report on the tax imposed under chapter 18 
of the Internal Revenue Code of 1986 (as added by this 
Act), including any issues related to the administration 
and enforcement of such tax. 
SEC. 3. STRENGTHENING DISCLOSURE REQUIREMENTS. 
(a) REGULATORY AUTHORITY.—The Secretary of the 
Treasury (or the Secretary’s delegate) may issue such 
rules and regulations as necessary to prevent taxpayers 
from avoiding the purpose of information reporting re-
quirements under the Internal Revenue Code of 1986 by 
placing assets in any foreign corporation, partnership, or 
trust in which the taxpayer holds directly or indirectly, 
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a significant interest as the sole or principal owner or the 
sole or principal beneficial owner. 
(b) FATCA ENFORCEMENT PLAN.—The Secretary 
of the Treasury (or the Secretary’s delegate) shall develop 
a comprehensive plan for managing efforts to leverage 
data collected under chapter 4 of the Internal Revenue 
Code of 1986 in agency compliance efforts. Such plan 
shall include an evaluation of the extent to which actions 
being undertaken as of the date of the enactment of this 
Act for the enforcement of the requirements of such chap-
ter improve voluntary compliance and address noncompli-
ance with such requirements. 
SEC. 4. INTERNAL REVENUE SERVICE FUNDING. 
(a) IN GENERAL.—Subchapter A of chapter 80 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new section: 
‘‘SEC. 7813. AUTHORIZATION OF APPROPRIATIONS. 
‘‘There are authorized to be appropriated to the Sec-
retary for each of fiscal years 2022 through 2032— 
‘‘(1) 
for 
enforcement 
of 
this 
title, 
$70,000,000,000, 
‘‘(2) for taxpayer services, $10,000,000,000, 
and 
‘‘(3) 
for 
business 
system 
modernization, 
$20,000,000,000.’’. 
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(b) CLERICAL AMENDMENT.—The table of sections 
for subchapter A of chapter 80 of the Internal Revenue 
Code of 1986 is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 7813. Authorization of appropriations.’’. 
Æ 
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