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Creates a new minimum "fair share" tax on the highest-income taxpayers by inserting a new part into Subchapter A of the Internal Revenue Code; the change applies to taxable years beginning after December 31, 2024. The bill also includes a nonbinding statement urging Congress to pursue broader tax reform to close loopholes, simplify the code, and ensure the wealthiest pay a larger share, and describes this change as a short-term floor intended to raise revenue and reduce the deficit.
Adds a new part at the end of Subchapter A of the Internal Revenue Code of 1986 to establish a provision titled “Fair share tax on high-income taxpayers.”
Makes a clerical amendment by adding a new item at the end of the table of parts for Subchapter A of the Internal Revenue Code of 1986 to list the new part.
Specifies that the amendments made by this section apply to taxable years beginning after December 31, 2024.
Congress should enact tax reform that (a) repeals unfair and unnecessary tax loopholes and expenditures, (b) simplifies the system for millions of taxpayers and businesses, and (c) makes sure that the wealthiest taxpayers pay a fair share.
This Act is described as an interim step that (a) can be done quickly, (b) can serve as a floor on taxes for the highest-income taxpayers, (c) can cut the deficit by billions of dollars a year, and (d) can help encourage more fundamental reform of the tax system.
Who is affected and how:
Highest-income taxpayers / highly compensated individuals: Directly affected — the core change creates a new minimum tax obligation that will increase tax liability for taxpayers whose current federal tax falls below the new floor. The exact impact depends on the statutory formula, thresholds, and interactions with existing credits and deductions (not detailed in the summary provided).
Taxpayers and tax preparers generally: Moderately affected — taxpayers near the top of the income distribution and their advisors will need to calculate the new minimum tax and may change tax planning strategies. Tax preparers must update software and compliance procedures.
Internal Revenue Service and federal tax administration: Moderately affected — the IRS must implement rules, guidance, forms, and processing changes to administer the new statutory provision.
Federal budget and deficit: Benefited — the bill is presented as increasing revenue and reducing the deficit by billions per year, though actual amounts depend on legislative details and enforcement.
Businesses and other taxpayers not in the top income tiers: Largely unaffected directly — unless provisions extend to passthrough income allocations or otherwise alter business tax items in detailed rules not included here. The legislation as summarized targets high‑income taxpayers rather than broad business tax changes.
Potential secondary effects:
Uncertainties:
Read twice and referred to the Committee on Finance.
Introduced April 1, 2025 by Sheldon Whitehouse · Last progress April 1, 2025
Expand sections to see detailed analysis
Read twice and referred to the Committee on Finance.
Introduced in Senate