S. 2845
Introduced in Senate · October 10, 2025September 17 (
legislative day
, September 16), 2025
Mr. Wyden (for himself, Mr. Whitehouse, Ms. Warren, Mr. Sanders, Ms. Smith, Mr. Luján, Mr. Welch, Ms. Alsobrooks, Ms. Baldwin, Mr. Blumenthal, Ms. Duckworth, Mr. Fetterman, Mr. Heinrich, Ms. Hirono, Mr. Markey, Mr. Merkley, Mr. Murphy, Mrs. Murray, Mr. Reed, Mr. Schatz, and Mr. Van Hollen) introduced the following bill; which was read twice and referred to the Committee on Finance
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