I 
119TH CONGRESS 
1ST SESSION H. R. 4462 
To amend the Internal Revenue Code of 1986 to impose an excise tax 
on certain investments of private colleges and universities. 
IN THE HOUSE OF REPRESENTATIVES 
JULY 16, 2025 
Mr. MURPHY 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 
an excise tax on certain investments of private colleges 
and universities. 
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 ‘‘Protecting Endow-
ments from Our Adversaries Act’’. 
SEC. 2. EXCISE TAX ON CERTAIN INVESTMENTS OF PRI-
VATE COLLEGES AND UNIVERSITIES. 
(a) IN GENERAL.—Subchapter H of chapter 42 of 
the Internal Revenue Code of 1986 is amended by adding 
at the end the following new section: 
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‘‘SEC. 4969. EXCISE TAX ON CERTAIN INVESTMENTS OF PRI-
VATE COLLEGES AND UNIVERSITIES. 
‘‘(a) TAX
ON ACQUISITION
OF LISTED INVEST-
MENTS.—In the case of any specified educational institu-
tion which acquires (directly or indirectly through any 
chain of ownership) one or more listed investments during 
any taxable year, there is hereby imposed for such taxable 
year a tax equal to 50 percent of the fair market values 
of such investments determined as of the dates of such 
acquisitions. 
‘‘(b) TAX ON NET INCOME FROM 1-YEAR LISTED IN-
VESTMENTS.— 
‘‘(1) IN GENERAL.—There is hereby imposed on 
each specified educational institution for the taxable 
year a tax equal to 100 percent of the excess (if 
any) of— 
‘‘(A) the sum of— 
‘‘(i) all income received with respect 
to any 1-year listed investment during such 
taxable year, plus 
‘‘(ii) all gains recognized with respect 
to the sale or other disposition of any 1- 
year listed investments during such taxable 
year, over 
‘‘(B) the sum of— 
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‘‘(i) all deductions properly allocable 
to income described in subparagraph 
(A)(i), plus 
‘‘(ii) all losses recognized with respect 
to the sale or other disposition of any 1- 
year listed investments during such taxable 
year. 
‘‘(2) 1-YEAR LISTED INVESTMENT.—For pur-
poses of this section, with respect to any income re-
ceived or gain or loss recognized, the term ‘1-year 
listed investment’ means any listed investment which 
was such a listed investment at all times during the 
1-year period ending on the date such income was 
received or such gain or loss was recognized. 
‘‘(c) LISTED INVESTMENT.—For purposes of this 
section— 
‘‘(1) IN
GENERAL.—The term ‘listed invest-
ment’ means any specified interest with respect to 
any person listed on one or more of— 
‘‘(A) the Entity List maintained by the 
Secretary of Commerce, 
‘‘(B) the Military End User (MEU) List 
maintained by the Secretary of Commerce, 
‘‘(C) the Unverified List maintained by the 
Secretary of Commerce, or 
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‘‘(D) the list maintained by the Federal 
Communications Commission of equipment and 
services covered by section 2 of the Secure and 
Trusted Communications Networks Act of 2019 
(commonly referred to as the FCC Covered 
List). 
‘‘(2) LISTED
PERSONS
LIST.—The Secretary 
shall establish (not later than 60 days after the date 
of the enactment of this section), update, and main-
tain a list of the persons which are listed on one or 
more of the lists described in paragraph (1). 
‘‘(3) SPECIFIED INTEREST.—The term ‘speci-
fied interest’ means, with respect to any person— 
‘‘(A) stock or any other equity or profits 
interest of such person, 
‘‘(B) debt issued by such person, or 
‘‘(C) any contract or derivative with re-
spect to any interest described in subparagraph 
(A) or (B). 
‘‘(4) INCLUSION OF CERTAIN POOLED FUNDS.— 
‘‘(A) IN GENERAL.—Any specified interest 
acquired through a regulated investment com-
pany, exchange traded fund, or any other 
pooled investment shall not fail to be treated as 
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