I 
119TH CONGRESS 
1ST SESSION H. R. 3588 
To amend the Internal Revenue Code of 1986 to require all real estate 
purchases by non-citizens to be reported to the Internal Revenue Service, 
to impose a tax on the purchase of real estate purchases by certain 
non-citizens, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MAY 23, 2025 
Mr. HARRIGAN introduced the following bill; which was referred to the Com-
mittee on Ways and Means, and in addition to the Committee on Foreign 
Affairs, for a period to be subsequently determined by the Speaker, in 
each case for consideration of such provisions as fall within the jurisdic-
tion of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to require 
all real estate purchases by non-citizens to be reported 
to the Internal Revenue Service, to impose a tax on 
the purchase of real estate purchases by certain non- 
citizens, 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 ‘‘Real Estate Reci-
procity Act’’. 
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SEC. 2. RETURNS WITH RESPECT TO FOREIGN PERSONS 
HOLDING DIRECT INVESTMENTS IN UNITED 
STATES REAL PROPERTY INTERESTS. 
(a) REQUIRED RETURN.—Section 6039C(a) of the 
Internal Revenue Code of 1986 is amended by striking 
‘‘To the extent provided in regulations, any’’ and inserting 
‘‘Any’’. 
(b) 
DOLLAR
THRESHOLD
REMOVED.—Section 
6039C(b) of such Code is amended by striking ‘‘during 
any calendar year if—’’ and all that follows through the 
period and inserting ‘‘during any calendar year if such 
person did not engage in a trade or business in the United 
States at any time during such calendar year’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to returns filed with respect to tax-
able years beginning after the date of the enactment of 
this Act. 
SEC. 3. REPORT ON FOREIGN PROHIBITION OF UNITED 
STATES OWNERSHIP OF REAL PROPERTY IN-
TERESTS. 
Not later than 60 days after the date of the enact-
ment of this Act, and annually thereafter, the Secretary 
of State shall provide to the Secretary of the Treasury 
a report describing all foreign countries that prohibit the 
purchase or ownership of real estate by citizens of the 
United States. 
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SEC. 4. IMPOSITION OF TAX ON THE ACQUISITION OF 
UNITED STATES REAL PROPERTY BY DIS-
QUALIFIED PERSONS. 
(a) IN GENERAL.—Subtitle D is amended by insert-
ing after chapter 50A the following new chapter: 
‘‘CHAPTER 50B—ACQUISITION OF UNITED 
STATES 
REAL 
PROPERTY 
BY 
DIS-
QUALIFIED PERSONS 
‘‘Sec. 5000E. Imposition of tax on acquisition of United States real property 
by disqualified persons. 
‘‘SEC. 5000E. IMPOSITION OF TAX ON ACQUISITION OF 
UNITED STATES REAL PROPERTY BY DIS-
QUALIFIED PERSONS. 
‘‘(a) IN GENERAL.—In the case of any acquisition of 
any United States real property by any disqualified per-
son, there is hereby imposed on such person a tax equal 
to 50 percent of the amount paid for such interest. 
‘‘(b) DISQUALIFIED PERSON.—For purposes of this 
section— 
‘‘(1) IN GENERAL.—The term ‘disqualified per-
son’ means— 
‘‘(A) any citizen of a disqualified country 
(other than a citizen, or lawful permanent resi-
dent, of the United States), 
‘‘(B) any entity domiciled in a disqualified 
country, 
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‘‘(C) any disqualified country and any po-
litical subdivision, agency, or instrumentality 
thereof, and 
‘‘(D) except as provided in paragraph (3), 
any entity if persons described in subparagraph 
(A), (B), or (C) (in the aggregate) 10-percent 
control such entity. 
‘‘(2) DISQUALIFIED COUNTRY.—The term ‘dis-
qualified country’ means any country identified in 
the report described in section 3 of the Real Estate 
Reciprocity Act. 
‘‘(3) EXCEPTION
FOR
CERTAIN
NON-CITI-
ZENS.—An individual shall not be treated as de-
scribed in paragraph (1)(A) if such individual re-
sides in the United States during the taxable year 
due to— 
‘‘(A) diplomatic obligations, or 
‘‘(B) a grant of asylum by the United 
States. 
‘‘(4) EXCEPTION
FOR
CERTAIN
PUBLICLY 
TRADED CORPORATIONS.— 
‘‘(A) IN GENERAL.—An entity shall not be 
treated as described in paragraph (1)(D) if— 
‘‘(i) such entity is a specified publicly 
traded corporation, or 
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‘‘(ii) specified publicly traded corpora-
tions (in the aggregate) control such enti-
ty. 
‘‘(B) SPECIFIED PUBLICLY TRADED COR-
PORATION.— 
‘‘(i) IN GENERAL.—The term ‘speci-
fied publicly traded corporation’ means any 
corporation if— 
‘‘(I) the stock of such corporation 
is regularly traded on an established 
securities 
market 
located 
in 
the 
United States, and 
‘‘(II) specified disqualified per-
sons do not (in the aggregate) control 
such corporation. 
‘‘(ii) SPECIFIED
DISQUALIFIED
PER-
SONS.—The term ‘specified disqualified 
persons’ means, with respect to any cor-
poration referred to in clause (i), any per-
son which— 
‘‘(I) is described in subparagraph 
(A), (B), or (C) of paragraph (1), and 
‘‘(II) 10-percent controls such 
corporation. 
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‘‘(c) PRORATED TAX ON ACQUISITIONS BY ENTITIES 
NOT MORE THAN 50 PERCENT CONTROLLED BY DIS-
QUALIFIED PERSONS.— 
‘‘(1) IN GENERAL.—In the case of any disquali-
fied person described in subsection (b)(1)(D) with 
respect to which persons described in subparagraphs 
(A), (B), or (C) of subsection (b)(1) do not (in the 
aggregate) control such disqualified person, sub-
section (a) shall be applied by substituting ‘the ap-
plicable percentage of the amount’ for ‘the amount’. 
‘‘(2) APPLICABLE PERCENTAGE.—For purposes 
of this section, the term ‘applicable percentage’ 
means, with respect to any disqualified person to 
which paragraph (1) applies, the highest percentage 
which could be substituted for ‘50 percent’ both 
places it appears in section 954(d)(3) without caus-
ing persons described in subparagraph (A), (B), or 
(C) of subsection (b)(1) (in the aggregate) to control 
(determined by taking into account such substi-
tution) such disqualified person. 
‘‘(d) CONTROL.—For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘control’ has the 
meaning given such term under section 954(d)(3), 
determined by treating the rules of section 958(a)(2) 
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as applying to both foreign and domestic corpora-
tions, partnerships, trusts, and estates. 
‘‘(2) 10-PERCENT
CONTROL.—The term ‘10- 
percent control’ means control (as defined in para-
graph (1)), determined by substituting ‘10 percent’ 
for ‘50 percent’ both places it appears in section 
954(d)(3). 
‘‘(e) UNITED STATES REAL PROPERTY.—The term 
‘United States real property’ has the meaning which would 
be given the term ‘United States real property interest’ 
by section 897(c) if— 
‘‘(1) paragraph (1)(A)(ii) were applied by sub-
stituting ‘such corporation was not a United States 
real property holding corporation at the time of ac-
quisition’ for ‘such corporation’ and all that follows, 
‘‘(2) paragraph (1)(B) did not apply, and 
‘‘(3) paragraph (3) were applied by substituting 
‘at the time of acquisition’ for ‘at some time during 
the shorter of the periods described in paragraph 
(1)(A)(ii)’.’’. 
(b) REPORTING REQUIREMENTS.— 
(1) IN GENERAL.—Subpart B of part III of 
subchapter A of chapter 61 is amended by adding at 
the end the following new section: 
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‘‘SEC. 6050AA. RETURNS RELATING TO ACQUISITION OF 
UNITED STATES REAL PROPERTY BY DIS-
QUALIFIED PERSONS. 
‘‘(a) IN GENERAL.—The required reporting person, 
with respect to any acquisition of any United States real 
property by a presumptively disqualified person to which 
section 5000E(a) applies, shall make a return at such time 
as the Secretary may provide setting forth— 
‘‘(1) the name, address, and TIN of such pre-
sumptively disqualified person, 
‘‘(2) a description of such United States real 
property (including the street address, if applicable), 
and 
‘‘(3) the amount paid for such United States 
real property. 
‘‘(b) STATEMENT TO BE FURNISHED TO PRESUMP-
TIVELY DISQUALIFIED PERSON.—Every person required 
to make a return under subsection (a) shall furnish, at 
such time as the Secretary may provide, to each presump-
tively disqualified person whose name is required to be set 
forth in such return a written statement showing— 
‘‘(1) the name and address of the information 
contact of the required reporting person, and 
‘‘(2) the information described in paragraphs 
(1), (2), and (3) of subsection (a) which relates to 
such disqualified person. 
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‘‘(c) REQUIRED REPORTING PERSON.—For purposes 
of this section, the term ‘required reporting person’ 
means, with respect to any acquisition of any United 
States real property— 
‘‘(1) the person (including any attorney or title 
company) responsible for closing the transaction in 
which such United States real property is acquired, 
or 
‘‘(2) if no one is responsible for closing such 
transaction (or in such other cases as the Secretary 
may provide), the transferor of such United States 
real property. 
‘‘(d) PRESUMPTIVELY DISQUALIFIED PERSON.—For 
purposes of this section, the term ‘presumptively disquali-
fied person’ means any person unless such person fur-
nishes to the required reporting person an affidavit by the 
such person stating, under penalty of perjury, that such 
person is not a disqualified person (as defined in section 
5000E(b)). 
‘‘(e) REQUIREMENT TO REQUEST AFFIDAVIT.—If 
the required reporting person, with respect to any acquisi-
tion of any United States real property, has not, as of 
the time of such acquisition, been furnished the affidavit 
described in subsection (d) by the acquirer of such inter-
est, such required reporting person shall furnish to such 
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acquirer, at such time, a written statement informing such 
acquirer of the required reporting person’s obligation to 
make the return described in subsection (a) with respect 
to such acquisition and including such other information 
as the Secretary may require. 
‘‘(f) UNITED STATES REAL PROPERTY.—For pur-
poses of this section, the term ‘United States real prop-
erty’ has the meaning given such term in section 5000E.’’. 
(2) PENALTIES.—Section 6724(d) is amend-
ed— 
(A) in paragraph (1)(B), by striking ‘‘or’’ 
at the end of clause (xxvii), by striking ‘‘and’’ 
at the end of clause (xxviii) and inserting ‘‘or’’, 
and by adding at the end the following new 
clause: 
‘‘(xxix) section 6050AA(a) (relating to 
returns relating to acquisition of United 
States real property by disqualified per-
sons), and’’, and 
(B) in paragraph (2), by striking ‘‘or’’ at 
the end of subparagraph (KK), by striking the 
period at the end of subparagraph (LL) and in-
serting ‘‘, or’’, and by inserting after subpara-
graph (LL) the following new subparagraph: 
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