Billionaires Income Tax Act

The Billionaires Income Tax Act (S 2845) would require high-net-worth individuals with at least $1 billion in assets or $100 million in annual income (or $500 million/$50 million for married filing separately) to pay taxes annually on investment gains rather than deferring taxes until assets are sold. It implements "mark-to-market" taxation for tradable assets like stocks and closes loopholes that allow tax-free transfers of assets to heirs, eliminating strategies like "buy, borrow, die." The bill targets "applicable taxpayers" by requiring annual tax payments on investment gains and modifies special tax provisions for investments in small business stock and qualified opportunity funds. The law would apply to individuals meeting either the asset or income test for three consecutive years, with specific rules for married couples and trusts.