[Congressional Bills 118th Congress]
[From the U.S. Government Publishing Office]
[H.R. 10028 Introduced in House (IH)]
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118th CONGRESS
2d Session
H. R. 10028
To amend the Internal Revenue Code of 1986 to disallow the deduction of
certain expenses relating to ownership of single-family homes by
specified large investors, to impose an excise tax on the sale of such
homes by such investors, and to prohibit Federal mortgage assistance
relating to certain large investors.
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IN THE HOUSE OF REPRESENTATIVES
October 22, 2024
Mr. Khanna (for himself, Ms. Porter, Mr. Takano, Mr. Grijalva, Mr.
Frost, Mrs. Cherfilus-McCormick, Mrs. Watson Coleman, Mr. Jackson of
Illinois, Mr. Deluzio, and Ms. Lee of California) introduced the
following bill; which was referred to the Committee on Ways and Means,
and in addition to the Committee on Financial Services, for a period to
be subsequently determined by the Speaker, in each case for
consideration of such provisions as fall within the jurisdiction of the
committee concerned
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A BILL
To amend the Internal Revenue Code of 1986 to disallow the deduction of
certain expenses relating to ownership of single-family homes by
specified large investors, to impose an excise tax on the sale of such
homes by such investors, and to prohibit Federal mortgage assistance
relating to certain large investors.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Stop Wall Street Landlords Act of
2024''.
SEC. 2. DISALLOWANCE OF DEDUCTION OF CERTAIN EXPENSES RELATED TO
SINGLE-FAMILY HOMES HELD BY SPECIFIED LARGE INVESTORS.
(a) In General.--Part IX of subchapter B of Chapter 1 of subtitle A
of the Internal Revenue Code of 1986 is amended by adding at the end
the following new section:
``SEC. 280I. CERTAIN EXPENSES RELATED TO SINGLE-FAMILY HOMES HELD BY
SPECIFIED LARGE INVESTORS.
``(a) In General.--In the case of a specified large investor, no
deduction shall be allowed under this chapter for the following
expenses relating to the ownership of a single-family home:
``(1) Amounts paid or incurred for the interest on a
mortgage relating to such single-family home or to insure such
single-family home.
``(2) Depreciation of such single-family home.
``(b) Specified Large Investor.--For purposes of this section--
``(1) In general.--The term `specified large investor'
means any person for any taxable year if the aggregate fair
market value of all assets of such person (reduced by the
aggregate debts of the taxpayer) exceeds $100,000,000 at any
time during such taxable year.
``(2) Treatment of controlled groups.--For purposes of this
subsection--
``(A) In general.--All persons which are part of a
controlled group (within the meaning of section 1563(a)
applied by substituting `more than 50 percent' for `at
least 80 percent' each place it appears) shall be
treated as 1 person.
``(B) Nonincorporated persons under common
control.--Under regulations or other guidance provided
by the Secretary, principles similar to the principles
of subparagraph (A) shall apply to a group of persons
under common control where 1 or more of such persons is
not a corporation.
``(3) Government entities and certain tax-exempt
entities.--Such term shall not include either of the following:
``(A) Any governmental entity.
``(B) Any organization which is described in
section 501(c)(3) and exempt from tax under section
501(a).
``(c) Single-Family Home.--
``(1) In general.--For purposes of this section, the term
`single-family home' means any real property located in the
United States if such property includes at least 1 dwelling
unit and not more than 4 dwelling units.
``(2) Exception for federally-assisted buildings.--For
purposes of this section--
``(A) In general.--Such term shall not include any
federally-assisted building.
``(B) Federally-assisted building.--The term
`federally-assisted building' means any building--
``(C) which is substantially assisted, financed, or
operated under section 8 of the United States Housing
Act of 1937, section 221(d)(3), 221(d)(4), or 236 of
the National Housing Act, section 515 of the Housing
Act of 1949, or any other housing program administered
by the Department of Housing and Urban Development or
by the Rural Housing Service of the Department of
Agriculture,
``(D) with respect to which a credit is allowed to
the taxpayer under section 42, or
``(E) for which financing is provided by a
qualified bond (within the meaning of section 141).
``(d) Exceptions.--
``(1) Principal residence.--In the case of a specified
large investor who is an individual, subsection (a) shall not
apply to any single-family home if such home is used as the
principal residence of such investor.
``(2) Original construction or substantial
rehabilitation.--Subsection (a) shall not apply with respect to
a single-family home originally constructed or substantially
rehabilitated (as defined in section 47(c)) by the taxpayer.''.
(b) Clerical Amendment.--The table of sections for part IX of
subchapter B of chapter 1 of such Code is amended by inserting after
the item relating to section 280H the following new item:
``Sec. 280I. Certain expenses related to single-family homes held by
specified large investors.''.
(c) Effective Date.--The amendments made by this section shall
apply to amounts paid or incurred and depreciation that occurs after
the date that is 18 months after the date of the enactment of this Act.
SEC. 3. EXCISE TAX ON TRANSFERS OF SINGLE-FAMILY HOMES BY SPECIFIED
LARGE INVESTORS.
(a) In General.--Subchapter C of chapter 36 of subtitle D of the
Internal Revenue Code of 1986 is amended to read as follows:
``Subchapter C--Tax on Transfers of Single-Family Homes by Specified
Large Investors
``Sec. 4471. Tax on transfers of single-family homes by specified large
investors.
``SEC. 4471. TAX ON TRANSFERS OF SINGLE-FAMILY HOMES BY SPECIFIED LARGE
INVESTORS.
``(a) In General.--There is hereby imposed a tax on the sale or
transfer of a single-family home by a specified large investor in an
amount equal to the sale price of the single-family home.
``(b) Specified Large Investor; Single-Family Home.--For purposes
of this section, the terms `specified large investor' and `single-
family home' shall have the respective meanings given such terms in
section 280I.
``(c) Special Rules.--Rules similar to the rules of subsections
(b)(2), (d)(1), and (d)(2) of 280I shall apply for purposes of this
section.''.
(b) Clerical Amendment.--The table of subchapters for chapter 36 of
subtitle D of such Code is amended by adding after the item relating to
subchapter B the following new item:
``Subchapter C. Tax on transfers of
single family homes by
specified large investors.''.
(c) Effective Date.--The amendments made by this section shall
apply to sales and transfers occurring after the date that is 18 months
after the date of the enactment of this Act.
SEC. 4. LOW-INCOME HOUSING ASSISTANCE.
(a) Deposit of Funds.--There are hereby transferred to the Housing
Trust Fund established under section 1338 of the Federal Housing
Enterprises Financial Safety and Soundness Act of 1992 (12 U.S.C. 4568)
amounts equivalent to the taxes received in the Treasury under section
4471 of the Internal Revenue Code of 1986.
(b) Use of Funds.--To the extent provided for in advance in
appropriations Acts, the amounts deposited in the Fund pursuant to
subsection (a) shall be used to increase and preserve the supply of
rental housing affordable to extremely low- and very low-income
families, including homeless families, in accordance with such section
1338.
SEC. 5. PROHIBITIONS ON FEDERAL MORTGAGE ASSISTANCE.
(a) Fannie Mae and Freddie Mac.--Subpart A of part 2 of subtitle A
of title XIII of the Housing and Community Development Act of 1992 (12
U.S.C. 4541 et seq.) is amended by adding at the end the following new
section:
``SEC. 1329. PROHIBITION RELATING TO SPECIFIED LARGE INVESTORS.
``The Director shall, by regulation, prohibit the enterprises from
newly purchasing any mortgage on a single-family housing or any portion
thereof (or any interest in such a mortgage), and from newly lending on
the security of or securitizing any such mortgage under which the
mortgagee is a specified large investor (as such term is defined in
section 280I of the Internal Revenue Code of 1986).''.
(b) Ginnie Mae.--Section 302(c) of the National Housing Act (12
U.S.C. 1717(c)) is amended by adding at the end the following new
paragraph:
``(6) The Association may not newly guarantee the payment
of principal of or interest on any trust certificate or other
security based or backed by a trust or pool that contains, or
purchase or acquire, any mortgage under which the mortgagee is
a specified large investor (as such term is defined in section
280I of the Internal Revenue Code of 1986).''.
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