H.R.5427

H. R. 5427

September 17, 2025

Mr. Cohen (for himself, Mr. Beyer, Ms. Tlaib, Mr. García of Illinois, Mr. McGovern, Ms. Norton, Mr. Davis of Illinois, Ms. DeLauro, Mr. Boyle of Pennsylvania, Ms. McCollum, Mr. Nadler, Mr. Garamendi, Ms. Kelly of Illinois, Ms. Dean of Pennsylvania, Mr. Mullin, Ms. Omar, Mr. Landsman, Ms. Scanlon, Ms. Clarke of New York, Mr. Huffman, Mr. Norcross, Ms. Sánchez, Mr. Evans of Pennsylvania, Mr. Frost, Ms. Lee of Pennsylvania, Ms. Simon, Mr. Jackson of Illinois, and Mrs. Ramirez) 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 eliminate tax loopholes that allow billionaires to defer tax indefinitely through planning strategies such as “buy, borrow, die”, to modify over 30 tax provisions so that billionaires are required to pay taxes annually, and for other purposes.

1. Short title; amendment of 1986 Code; table of contents; 2. Purpose; TITLE I—ELIMINATION OF DEFERRAL FOR APPLICABLE TAXPAYERS; 101. Elimination of deferral of tax; 102. Carryback of capital losses attributable to mark-to-market rules; TITLE II—APPLICATION OF OTHER PROVISIONS TO APPLICABLE TAXPAYERS AND ENTITIES; 201. Applicable taxpayers not eligible for adjusted gross income limitation on net investment tax; 202. Treatment of covered expatriates; 211. Treatment of like-kind exchanges by applicable entities; 212. Treatment of transfers by applicable entities in exchange for stock; 213. Special rules for applicable trusts; 221. Elimination of deferral of tax on certain compensation; 222. Rules relating to certain life insurance and annuity contracts of applicable taxpayers; 231. Treatment of exclusion for certain small business stock; 232. Modifications for investments in qualified opportunity funds

Elimination of deferral for applicable taxpayers

Special rules for applicable foreign trusts

Returns relating to amounts received under certain life insurance and annuity contracts