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Creates new tax rules aimed at limiting purchases and rental ownership of single-family homes by hedge-fund–style investors. It imposes an excise tax on acquisitions of single-family residences by qualifying hedge fund taxpayers, raises the corporate tax rate for certain corporations tied to those taxpayers, and denies key tax deductions (interest, depreciation, and the qualified business income deduction) for hedge-fund landlords who operate in the single-family rental market. The changes target entities defined as “hedge fund taxpayers” and apply to 1–4 unit residential properties; most deduction limits take effect for tax years beginning Jan 1, 2031, while the corporate tax-rate increase and the QBI deduction exclusion begin Jan 1, 2036. The excise tax on acquisitions applies to taxable years beginning after enactment.
The bill aims to limit institutional acquisition advantages and raise revenue by targeting hedge-fund ownership of single-family homes, but does so at the risk of higher housing costs, reduced institutional investment in rental housing, and added tax complexity.
Homebuyers, renters, and small landlords will likely face less competition from institutional investors/hedge funds buying single-family homes, which can ease upward pressure on local home prices and rents.
Taxpayers and the federal government: the bill raises federal revenue through an excise tax on certain institutional home acquisitions and by increasing the corporate tax rate for specified hedge-fund corporations, which can fund public services or reduce deficits.
Taxpayers broadly: the measure narrows tax advantages for large institutional owners (e.g., by denying certain deductions), improving perceived tax fairness and leveling the playing field with smaller landlords.
Renters, homebuyers, and middle-class families may see higher rents and/or higher home prices if institutional owners pass on higher taxes and lost deductions, or if reduced investment tightens supply.
Hedge-fund-backed institutional owners, their investors, and employees will face higher tax liabilities (including an increased corporate rate and loss of interest, depreciation, and QBI deductions), likely reducing after-tax returns and dampening investment, maintenance, and hiring in rental housing.
Taxpayers and the IRS will bear greater compliance, administrative, and enforcement costs because the bill creates new excise rules, a special corporate-rate carve-out, and additional complexity that can invite tax planning and disputes.
Introduced February 26, 2026 by Jeff Merkley · Last progress February 26, 2026