I 
117TH CONGRESS 
2D SESSION 
H. R. 8582 
To amend the Internal Revenue Code of 1986 to impose an excise tax 
on the acquisition of single-family homes by certain large investors. 
IN THE HOUSE OF REPRESENTATIVES 
JULY 28, 2022 
Mr. SMITH of Washington introduced the following bill; which was referred to 
the Committee on Ways and Means, and in addition to the Committee 
on Financial Services, 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 
an excise tax on the acquisition of single-family homes 
by certain large investors. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. EXCISE TAX ON ACQUISITIONS OF SINGLE-FAM-
ILY HOMES BY CERTAIN LARGE INVESTORS. 
(a) IN GENERAL.—Chapter 36 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subchapter: 
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‘‘Subchapter E—Acquisition of Single-Family 
Homes by Large Investors 
‘‘Sec. 4491. Tax on acquisition of single-family homes by certain large inves-
tors. 
‘‘SEC. 4491. TAX ON ACQUISITION OF SINGLE-FAMILY 
HOMES BY CERTAIN LARGE INVESTORS. 
‘‘(a) TAX IMPOSED.—In the case of the sale of any 
single-family home to a specified large investor, there is 
hereby imposed a tax equal to 100 percent of the amount 
paid for such home. 
‘‘(b) BY WHOM PAID.—The tax imposed under sub-
section (a) shall be paid by the specified large investor. 
‘‘(c) SINGLE-FAMILY HOME.—For purposes of this 
section, the term ‘single-family home’ means any real 
property located in the United States if such property in-
cludes at least 1 dwelling unit and not more than 2 dwell-
ing units. 
‘‘(d) SPECIFIED LARGE INVESTOR.—For purposes of 
this section, the term ‘specified large investor’ means any 
person for any taxable year if the aggregate fair market 
value of all assets of such person (reduced by the aggre-
gate debts of the taxpayer) determined as of the beginning 
of such taxable year exceeds $20,000,000. Such term shall 
not include any governmental entity or any organization 
described in section 501(c) and exempt from tax under 
section 501(a). 
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‘‘(e) EXCEPTIONS.— 
‘‘(1) PRINCIPAL RESIDENCE.—In the case of a 
specified large investor who is an individual, sub-
section (a) shall not apply to the sale of any single- 
family home to such specified large investor if such 
home is used as the principal residence of such in-
vestor. 
‘‘(2) LOW-INCOME HOUSING PROGRAMS.—Sub-
section (a) shall not apply to the sale of any single- 
family home to a specified large investor if the ac-
quisition of such home by such investor is pursuant 
to a governmental program the purpose of which is 
to provide housing to low-income individuals. 
‘‘(f) CONTROLLED GROUPS.—For purposes of sub-
section (d)— 
‘‘(1) CORPORATIONS.— 
‘‘(A) IN GENERAL.—All persons treated as 
a controlled group shall be treated as 1 person. 
‘‘(B) CONTROLLED
GROUP.—The term 
‘controlled group’ has the meaning given to 
such term by subsection (a) of section 1563; ex-
cept that for such purposes the phrase ‘more 
than 50 percent’ shall be substituted for the 
phrase ‘at least 80 percent’ each place it ap-
pears in such subsection. 
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‘‘(2) NONINCORPORATED PERSONS UNDER COM-
MON
CONTROL.—Under regulations prescribed by 
the Secretary, principles similar to the principles of 
paragraph (1) shall apply to a group of persons 
under common control where 1 or more of such per-
sons is not a corporation. 
‘‘(g) TRANSFER OF REVENUES TO THE HOUSING 
TRUST FUND.— 
‘‘(1) IN GENERAL.—There are hereby appro-
priated to the Housing Trust Fund established 
under section 1338 of the Federal Housing Enter-
prises Financial Safety and Soundness Act of 1992 
amounts equivalent to the taxes received in the 
Treasury under this section. 
‘‘(2) ADMINISTRATION OF TRANSFERS.—Rules 
similar to the rules of section 9601 shall apply for 
purposes of this subsection.’’. 
(b) CLERICAL AMENDMENT.—The table of sub-
chapters for chapter 36 of such Code is amended by add-
ing at the end the following new item: 
‘‘SUBCHAPTER E. ACQUISITION OF SINGLE-FAMILY HOMES BY LARGE 
INVESTORS.’’. 
(c) ANNUAL REPORT.—With respect to each calendar 
year beginning after the date of the enactment of this Act, 
the Secretary of Housing and Urban Development shall 
make publicly available an annual report which evaluates 
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the trends in purchases of single-family homes (as defined 
in section 4491(c) of the Internal Revenue Code of 1986) 
by specified large investors (as defined in section 4491(d) 
of such Code). 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to sales after the date of the enact-
ment of this Act. 
Æ 
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