Congress targets billionaire wealth with annual tax on unrealized gains
S. 2845 — Billionaires Income Tax Act · Filed by Ron Wyden (D-OR) · 23 cosponsors · Introduced Sep 17, 2025 · Referred to committee
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What it does
This bill creates a new annual tax on ultra-wealthy individuals and certain trusts, targeting those with over $100 million in annual income or $1 billion in assets. It treats unrealized gains on most assets (stocks, real estate, business interests) as if they were sold each year, requiring billionaires to pay tax on the appreciation even if they haven't sold the asset. The tax applies to pass-through entities and includes complex reporting rules for partnerships and S-corporations to track gains.
Why we flagged it
The bill's core mechanism is an annual mark-to-market tax on unrealized gains for ultra-high-net-worth individuals and trusts. It is functionally a wealth tax disguised as an income tax, targeting the top 0.01% of earners and asset holders.
What the text implies
- Valuation disputes will likely dominate IRS enforcement; the bill allows taxpayers to self-value nontradable assets using multiple methods (cost basis, adjusted basis, financial statements, loan collateral value), creating significant audit risk and litigation.
- Pass-through entities (partnerships, S-corps) face new administrative burdens: tracking gains on nontradable assets, reporting to applicable taxpayers, and adjusting basis in tiered structures. Small business owners may face unexpected tax bills if they become 'significant owners' (5% stake or $50M+ in nontradable interests).
- The 5-year installment payment option for first-year applicable taxpayers may incentivize asset sales to avoid acceleration; disposition of assets triggers immediate payment of deferred tax, potentially forcing liquidity crises.
- Grantor trusts and certain estate planning structures receive special treatment (deemed sales on transfer), potentially disrupting multi-generational wealth transfer strategies and increasing estate tax exposure.
- Foreign persons and expatriates face lower thresholds ($50M income, $500M assets) and extended tracking periods (10 years post-expatriation), creating compliance complexity for international wealth holders.
Who it affects
Ordinary citizens benefit from a new revenue source targeting only the ultra-wealthy (roughly 700-1,000 households), reducing the tax burden on middle and working-class Americans. The tax addresses a long-standing fairness concern: billionaires paying lower effective tax rates than ordinary workers by deferring gains indefinitely. However, implementation complexity and potential economic distortions create real costs.
Who stands to gain
- U.S. Treasury / federal government
- Tax compliance and accounting firms
- Valuation and appraisal services
- IRS enforcement and litigation resources
Named in the bill
Internal Revenue Service (IRS), Secretary of the Treasury, Applicable taxpayers (individuals with $100M+ income or $1B+ assets), Applicable entities (partnerships, S-corporations, pass-through entities), Qualified opportunity funds, Charitable remainder trusts, Grantor trusts, Expatriates under section 877A
Where it stands
23 cosponsors: 22 Democrats, 1 Independents.
- Sep 17, 2025 — Introduced · Congress.gov: “Introduced in Senate”
- Sep 17, 2025 — Referred to Senate Committee on Finance · Congress.gov: “Read twice and referred to the Committee on Finance”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
8 lobbying clients named this bill on 9 disclosure filings across 2 quarters, Dec 2025 to Jun 2026. Those filings disclosed $2,514,577 in lobbying spend. A filing names 25 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 88% of bills with at least one filing.
Ron Wyden, the sponsor, reported $375,070 in PAC receipts in the 2026 cycle.
- Finseca — $1,080,000 on 2 filings
- American Federation of State County and Municipal Employees — $690,000 on 1 filing
- American Federation of Teachers — $410,000 on 1 filing
- Public Citizen — $99,577 on 1 filing
- National Women's Law Center Action Fund — $75,000 on 1 filing
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the full bill text on Jun 8, 2026; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.
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