A Bill to Tax Unrealized Capital Gains for Households Over $100M
Annual tax on unrealized capital gains for households with net worth above $100 million.
Households with net worth above $100 million shall pay annual income tax on unrealized capital gains in publicly traded assets.
Tax on illiquid assets deferred until disposition, with deferral interest charge.
Estimated to raise $360 billion over 10 years.
IRS implementation with high-net-worth audit division.
Mechanical parts, sourced & timed
Use this as your pre-round checklist. Memorize the source citation. Time yourself to the delivery target.
- Bill / Number
- S. 853 — A Bill to Tax Unrealized Capital Gains for Households Over $100M
- Funding source
- Estimated $360B over 10 years in new revenue.
- Timeline
- Effective at next tax year.
- Plausible mechanically; Moore v. United States (2024) limits set the constitutional ceiling.
- Enforcing agency
- IRS Large Business & International Division.
- Yes for income tax; unrealized-gains taxation constitutional only post-Moore (2024) narrow holding.
- Penalty for non-compliance
- IRS underpayment + accuracy penalties.
- Source citation
- Saez & Zucman (UC Berkeley, 2022), 'Top Wealth in America' — eml.berkeley.edu.
- Delivery time (read aloud)
- 1:15 (75s)
Taxing unrealized gains is unconstitutional under the 16th Amendment (Eisner v. Macomber, 1920).
Eisner v. Macomber was narrowed by Helvering v. Bruun (1940) and effectively limited by Moore v. United States (2024), which upheld the Mandatory Repatriation Tax on unrealized foreign earnings. Liquid publicly-traded gains for >$100M households fit comfortably within Moore's reasoning.