119-HR2912

Bill is currently in: House
Path to Law
House Senate President

119th CONGRESS

1st Session

H. R. 2912

1. Short title
2. Imposition of wealth tax

1. Short title

This Act may be cited as the "Oligarch Act of 2025".

2. Imposition of wealth tax

(a) In general - The Internal Revenue Code of 1986 is amended by inserting after subtitle B the following new subtitle:

(b) No deduction from income taxes - Section 275 of such Code is amended by inserting after paragraph (6) the following new paragraph:

(7) - Taxes imposed by chapter 18.

(c) Extension of time for payment of tax

(1) In general - Section 6161(a) of such Code is amended by adding at the end the following new paragraph:

(3) Wealth tax

(A) In general - In the case of an applicable taxpayer described in subparagraph (B), the Secretary may extend the time for payment of the tax imposed under chapter 18 for a reasonable period not to exceed 5 years from the date fixed for the payment thereof.

(B) Taxpayers described - An applicable taxpayer is described in this subparagraph if such the Secretary determines—

(i) - the applicable taxpayer has severe liquidity constraints, or

(ii) - immediate payment would cause undue hardship on an ongoing enterprise.

(C) Applicable taxpayer - For purposes of this paragraph, the term applicable taxpayer has the meaning given such term in section 2901.

(2) Rules - Not later than 12 months after the date of the enactment of this Act, the Secretary of the Treasury (or the Secretary's delegate) shall establish rules for the application of the amendments made by paragraph (1).

(d) Application of accuracy related penalties

(1) In general - Section 6662(b) of such Code is amended by inserting after paragraph (10) the following new paragraph:

(11) - Any substantial wealth tax valuation understatement.

(2) Substantial wealth tax understatement - Section 6662 of such Code is amended by adding at the end the following new subsection:

(m) Application to substantial wealth tax valuation understatement

(1) Substantial wealth tax valuation understatement defined

(A) In general - For purposes of this section, there is a substantial wealth tax valuation understatement if the value of any property claimed on any return of tax is 65 percent or less of the amount determined to be the correct amount of such valuation.

(B) Limitation - No penalty shall be imposed by reason of subsection (b)(11) unless the portion of the underpayment attributable to substantial wealth tax valuation understatements for the calendar year exceeds $5,000.

(2) Increased penalty

(A) In general - In the case of any portion of an underpayment which is attributable to one or more substantial wealth tax valuation understatement, subsection (a) shall be applied—

(i) - in the case of a substantial wealth tax valuation understatement which is a gross wealth tax valuation misstatement, by substituting "50 percent" for "20 percent", and

(ii) - in any other case, by substituting "30 percent" for "20 percent".

(B) Gross wealth tax valuation misstatement - For purposes of subparagraph (A), the term gross wealth tax valuation misstatement means a substantial wealth tax valuation understatement, as determined under paragraph (1) by substituting "40 percent" for "65 percent".

(e) Exemption of tax-Exempt entities - Section 501(a) of such Code is amended by inserting "and subtitle B–1" after "this subtitle".

(f) Clerical amendment - The table of subtitles of such Code is amended by inserting after the item relating to subtitle B the following new item:

(g) Effective date - The amendments made by this section shall apply to calendar years beginning after the date of the enactment of this Act.