I 
119TH CONGRESS 
1ST SESSION H. R. 2534 
To ensure high-income earners pay a fair share of Federal taxes. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 1, 2025 
Mr. BOYLE of Pennsylvania (for himself, Mr. KHANNA, and Ms. NORTON) in-
troduced the following bill; which was referred to the Committee on Ways 
and Means 
A BILL 
To ensure high-income earners pay a fair share of Federal 
taxes. 
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 ‘‘Paying a Fair Share 
Act of 2025’’. 
SEC. 2. FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS. 
(a) IN GENERAL.—Subchapter A of chapter 1 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new part: 
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‘‘PART VIII—FAIR SHARE TAX ON HIGH-INCOME 
TAXPAYERS 
‘‘Sec. 59B. Fair share tax. 
‘‘SEC. 59B. FAIR SHARE TAX. 
‘‘(a) GENERAL RULE.— 
‘‘(1) PHASE-IN OF TAX.—In the case of any 
high-income taxpayer, there is hereby imposed for a 
taxable year (in addition to any other tax imposed 
by this subtitle) a tax equal to the product of— 
‘‘(A) the amount determined under para-
graph (2), and 
‘‘(B) a fraction (not to exceed 1)— 
‘‘(i) the numerator of which is the ex-
cess of— 
‘‘(I) 
the 
taxpayer’s 
adjusted 
gross income, over 
‘‘(II) the dollar amount in effect 
under subsection (c)(1), and 
‘‘(ii) the denominator of which is the 
dollar amount in effect under subsection 
(c)(1). 
‘‘(2) AMOUNT OF TAX.—The amount of tax de-
termined under this paragraph is an amount equal 
to the excess (if any) of— 
‘‘(A) the tentative fair share tax for the 
taxable year, over 
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‘‘(B) the excess of— 
‘‘(i) the sum of— 
‘‘(I) the regular tax liability (as 
defined in section 26(b)) for the tax-
able year, determined without regard 
to any tax liability determined under 
this section, 
‘‘(II) the tax imposed by section 
55 for the taxable year, plus 
‘‘(III) the payroll tax for the tax-
able year, over 
‘‘(ii) the credits allowable under part 
IV of subchapter A (other than sections 
27(a), 31, and 34). 
‘‘(b) TENTATIVE FAIR SHARE TAX.—For purposes 
of this section— 
‘‘(1) IN GENERAL.—The tentative fair share tax 
for the taxable year is 30 percent of the excess of— 
‘‘(A) the adjusted gross income of the tax-
payer, over 
‘‘(B) the modified charitable contribution 
deduction for the taxable year. 
‘‘(2) MODIFIED
CHARITABLE
CONTRIBUTION 
DEDUCTION.—For purposes of paragraph (1)— 
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‘‘(A) IN
GENERAL.—The modified chari-
table contribution deduction for any taxable 
year is an amount equal to the amount which 
bears the same ratio to the deduction allowable 
under section 170 (section 642(c) in the case of 
a trust or estate) for such taxable year as— 
‘‘(i) the amount of itemized deduc-
tions allowable under the regular tax (as 
defined in section 55) for such taxable 
year, determined after the application of 
section 68, bears to 
‘‘(ii) such amount, determined before 
the application of section 68. 
‘‘(B) TAXPAYER
MUST
ITEMIZE.—In the 
case of any individual who does not elect to 
itemize deductions for the taxable year, the 
modified charitable contribution deduction shall 
be zero. 
‘‘(c) HIGH-INCOME TAXPAYER.—For purposes of this 
section— 
‘‘(1) IN GENERAL.—The term ‘high-income tax-
payer’ means, with respect to any taxable year, any 
taxpayer (other than a corporation) with an adjusted 
gross income for such taxable year in excess of 
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