I 
116TH CONGRESS 
1ST SESSION H. R. 4857 
To amend the Internal Revenue Code of 1986 to reinstate estate and 
generation-skipping taxes, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
OCTOBER 24, 2019 
Mr. GOMEZ (for himself, Mr. BLUMENAUER, Mr. CARSON of Indiana, Mr. 
CARTWRIGHT, Ms. JUDY CHU of California, Mr. COHEN, Mr. DANNY K. 
DAVIS of Illinois, Ms. DELAURO, Mr. DESAULNIER, Mr. DEFAZIO, Mr. 
MICHAEL F. DOYLE of Pennsylvania, Mr. ESPAILLAT, Mr. GARCI´A of Illi-
nois, Mr. GREEN of Texas, Mr. GRIJALVA, Ms. HAALAND, Ms. NORTON, 
Ms. JACKSON LEE, Ms. JAYAPAL, Mr. KHANNA, Ms. LEE of California, 
Mr. LEVIN of Michigan, Mr. LOWENTHAL, Mr. MCGOVERN, Mr. NAD-
LER, Mrs. NAPOLITANO, Ms. OCASIO-CORTEZ, Ms. OMAR, Mr. PAYNE, 
Mr. POCAN, Ms. PRESSLEY, Ms. SCHAKOWSKY, Mr. SERRANO, Mr. 
TAKANO, Mr. TONKO, Ms. TLAIB, Ms. VELA´ZQUEZ, and Mrs. WATSON 
COLEMAN) introduced the following bill; which was referred to the Com-
mittee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to reinstate 
estate and generation-skipping taxes, 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 ‘‘For the 99.8 Percent 
Act’’. 
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SEC. 2. MODIFICATIONS TO ESTATE, GIFT, AND GENERA-
TION-SKIPPING TRANSFER TAXES. 
(a) MODIFICATION OF RATES.—Section 2001(c) of 
the Internal Revenue Code of 1986 is amended by striking 
the last 2 rows and inserting the following: 
‘‘Over $750,000 but not over $3,500,000 .............
$248,300 plus 39 per-
cent of the excess of 
such amount over 
$750,000. 
Over $3,500,000 but not over $10,000,000 ........
$1,320,800 plus 45 
percent of the ex-
cess of such amount 
over $3,500,000. 
Over $10,000,000 but not over $50,000,000 ......
$4,245,800 plus 50 
percent of the ex-
cess of such amount 
over $10,000,000. 
Over $50,000,000 but not over $1,000,000,000
$24,245,800 plus 55 
percent of the ex-
cess of such amount 
over $50,000,000. 
Over $1,000,000,000 ...........................................
$546,745,800 plus 77 
percent of the ex-
cess of such amount 
over 
$1,000,000,000.’’. 
(b) EXCLUSION AMOUNT.— 
(1) ESTATE
TAX.—Paragraph (3) of section 
2010(c) of the Internal Revenue Code of 1986 is 
amended to read as follows: 
‘‘(3) BASIC
EXCLUSION
AMOUNT.—For pur-
poses of this section, the basic exclusion amount is 
$3,500,000.’’. 
(2) MODIFICATION
TO
GIFT
TAX
EXCLUSION 
AMOUNT.—Paragraph (1) of section 2505(a) of the 
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Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(1) the applicable credit amount in effect 
under section 2010(c) for such calendar year (deter-
mined as if the basic exclusion amount in section 
2010(c)(2)(A) were $1,000,000), reduced by’’. 
(3) MODIFICATIONS
OF
ESTATE
AND
GIFT 
TAXES TO REFLECT DIFFERENCES IN CREDIT RE-
SULTING FROM DIFFERENT EXCLUSION AMOUNTS.— 
(A) ESTATE
TAX
ADJUSTMENT.—Section 
2001 of the Internal Revenue Code of 1986 is 
amended by adding at the end the following 
new subsection: 
‘‘(h) ADJUSTMENT TO REFLECT CHANGES IN EX-
CLUSION AMOUNT.— 
‘‘(1) IN GENERAL.—If, with respect to any gift 
to which subsection (b)(2) applies, the applicable ex-
clusion amount in effect at the time of the dece-
dent’s death is less than such amount in effect at 
the time such gift is made by the decedent, the 
amount of tax computed under subsection (b) shall 
be reduced by the amount of tax which would have 
been payable under chapter 12 at the time of the 
gift if the applicable exclusion amount in effect at 
such time had been the applicable exclusion amount 
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in effect at the time of the decedent’s death and the 
modifications described in subsection (g) had been 
applicable at the time of such gifts. 
‘‘(2) LIMITATION.—The aggregate amount of 
gifts made in any calendar year to which the reduc-
tion under paragraph (1) applies shall not exceed 
the excess of— 
‘‘(A) the applicable exclusion amount in ef-
fect for such calendar year, over 
‘‘(B) the applicable exclusion amount in ef-
fect at the time of the decedent’s death. 
‘‘(3) APPLICABLE
EXCLUSION
AMOUNT.—The 
term ‘applicable exclusion amount’ means, with re-
spect to any period, the amount determined under 
section 2010(c) for such period, except that in the 
case of any period for which such amount includes 
the deceased spousal unused exclusion amount (as 
defined in section 2010(c)(4)), such term shall mean 
the basic exclusion amount (as defined under section 
2010(c)(3), as in effect for such period).’’. 
(B) GIFT
TAX
ADJUSTMENT.—Section 
2502 of such Code is amended by adding at the 
end the following new subsection: 
‘‘(d) ADJUSTMENT TO REFLECT CHANGES IN EX-
CLUSION AMOUNT.— 
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‘‘(1) IN GENERAL.—If the taxpayer made a tax-
able gift in an applicable preceding calendar period, 
the amount of tax computed under subsection (a) 
shall be reduced by the amount of tax which would 
have been payable under chapter 12 for such appli-
cable preceding calendar period if the applicable ex-
clusion amount in effect for such preceding calendar 
period had been the applicable exclusion amount in 
effect for the calendar year for which the tax is 
being computed and the modifications described in 
subsection (g) had been applicable for such pre-
ceding calendar period. 
‘‘(2) LIMITATION.—The aggregate amount of 
gifts made in any applicable preceding calendar pe-
riod to which the reduction under paragraph (1) ap-
plies shall not exceed the excess of— 
‘‘(A) the applicable exclusion amount for 
such preceding calendar period, over 
‘‘(B) the applicable exclusion amount for 
the calendar year for which the tax is being 
computed. 
‘‘(3) APPLICABLE PRECEDING CALENDAR YEAR 
PERIOD.—The term ‘applicable preceding calendar 
year period’ means any preceding calendar year pe-
riod in which the applicable exclusion amount ex-
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ceeded the applicable exclusion amount for the cal-
endar year for which the tax is being computed. 
‘‘(4) APPLICABLE
EXCLUSION
AMOUNT.—The 
term ‘applicable exclusion amount’ means, with re-
spect to any period, the amount determined under 
section 2010(c) for such period, except that in the 
case of any period for which such amount includes 
the deceased spousal unused exclusion amount (as 
defined in section 2010(c)(4)), such term shall mean 
the basic exclusion amount (as defined under section 
2010(c)(3), as in effect for such period).’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to estates of decedents dying, and 
generation-skipping transfers and gifts made, after De-
cember 31, 2019. 
SEC. 3. MODIFICATION OF RULES FOR VALUE OF CERTAIN 
FARM, ETC., REAL PROPERTY. 
(a) 
IN
GENERAL.—Paragraph 
(2) 
of 
section 
2032A(a) of the Internal Revenue Code of 1986 is amend-
ed by striking ‘‘$750,000’’ and inserting ‘‘$3,000,000’’. 
(b) INFLATION ADJUSTMENT.—Paragraph (3) of sec-
tion 2032A(a) of such Code is amended— 
(1) by striking ‘‘1998’’ and inserting ‘‘2019’’; 
(2) by striking ‘‘$750,000’’ each place it ap-
pears and inserting ‘‘$3,000,000’’; and 
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