Establishes a billionaire mark-to-market tax

The bill imposes a tax on New York residents with $1 billion or more in net assets (total assets minus debts) by calculating gains as if their assets were sold at market value on December 31, 2024. Taxable gains apply only to the value exceeding $1 billion, capped at 25% of that excess. Taxpayers may pay the full amount or in ten annual installments with an annual deferral charge based on estimated borrowing rates. It covers assets owned directly, through trusts, or held by family members, including those donated within five years.