I
119THCONGRESS
1
STSESSION H. R. 2534
To ensure high-income earners pay a fair share of Federal taxes.
IN THE HOUSE OF REPRESENTATIVES
APRIL1, 2025
Mr. B
OYLEof Pennsylvania (for himself, Mr. KHANNA, and Ms. NORTON) in-
troduced the following bill; which was referred to the Committee on Ways
and Means
A BILL
To ensure high-income earners pay a fair share of Federal
taxes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Paying a Fair Share 4
Act of 2025’’. 5
SEC. 2. FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS. 6
(a) I
NGENERAL.—Subchapter A of chapter 1 of the 7
Internal Revenue Code of 1986 is amended by adding at 8
the end the following new part: 9
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‘‘PART VIII—FAIR SHARE TAX ON HIGH-INCOME 1
TAXPAYERS 2
‘‘Sec. 59B. Fair share tax.
‘‘SEC. 59B. FAIR SHARE TAX.
3
‘‘(a) G
ENERALRULE.— 4
‘‘(1) P
HASE-IN OF TAX.—In the case of any 5
high-income taxpayer, there is hereby imposed for a 6
taxable year (in addition to any other tax imposed 7
by this subtitle) a tax equal to the product of— 8
‘‘(A) the amount determined under para-9
graph (2), and 10
‘‘(B) a fraction (not to exceed 1)— 11
‘‘(i) the numerator of which is the ex-12
cess of— 13
‘‘(I) the taxpayer’s adjusted 14
gross income, over 15
‘‘(II) the dollar amount in effect 16
under subsection (c)(1), and 17
‘‘(ii) the denominator of which is the 18
dollar amount in effect under subsection 19
(c)(1). 20
‘‘(2) A
MOUNT OF TAX.—The amount of tax de-21
termined under this paragraph is an amount equal 22
to the excess (if any) of— 23
‘‘(A) the tentative fair share tax for the 24
taxable year, over 25
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‘‘(B) the excess of— 1
‘‘(i) the sum of— 2
‘‘(I) the regular tax liability (as 3
defined in section 26(b)) for the tax-4
able year, determined without regard 5
to any tax liability determined under 6
this section, 7
‘‘(II) the tax imposed by section 8
55 for the taxable year, plus 9
‘‘(III) the payroll tax for the tax-10
able year, over 11
‘‘(ii) the credits allowable under part 12
IV of subchapter A (other than sections 13
27(a), 31, and 34). 14
‘‘(b) T
ENTATIVEFAIRSHARETAX.—For purposes 15
of this section— 16
‘‘(1) I
N GENERAL.—The tentative fair share tax 17
for the taxable year is 30 percent of the excess of— 18
‘‘(A) the adjusted gross income of the tax-19
payer, over 20
‘‘(B) the modified charitable contribution 21
deduction for the taxable year. 22
‘‘(2) M
ODIFIED CHARITABLE CONTRIBUTION 23
DEDUCTION.—For purposes of paragraph (1)— 24
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‘‘(A) IN GENERAL.—The modified chari-1
table contribution deduction for any taxable 2
year is an amount equal to the amount which 3
bears the same ratio to the deduction allowable 4
under section 170 (section 642(c) in the case of 5
a trust or estate) for such taxable year as— 6
‘‘(i) the amount of itemized deduc-7
tions allowable under the regular tax (as 8
defined in section 55) for such taxable 9
year, determined after the application of 10
section 68, bears to 11
‘‘(ii) such amount, determined before 12
the application of section 68. 13
‘‘(B) T
AXPAYER MUST ITEMIZE .—In the 14
case of any individual who does not elect to 15
itemize deductions for the taxable year, the 16
modified charitable contribution deduction shall 17
be zero. 18
‘‘(c) H
IGH-INCOMETAXPAYER.—For purposes of this 19
section— 20
‘‘(1) I
N GENERAL.—The term ‘high-income tax-21
payer’ means, with respect to any taxable year, any 22
taxpayer (other than a corporation) with an adjusted 23
gross income for such taxable year in excess of 24
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$1,000,000 (50 percent of such amount in the case 1
of a married individual who files a separate return). 2
‘‘(2) I
NFLATION ADJUSTMENT .— 3
‘‘(A) I
N GENERAL.—In the case of a tax-4
able year beginning after 2025, the $1,000,000 5
amount under paragraph (1) shall be increased 6
by an amount equal to— 7
‘‘(i) such dollar amount, multiplied by 8
‘‘(ii) the cost-of-living adjustment de-9
termined under section 1(f)(3) for the cal-10
endar year in which the taxable year be-11
gins, determined by substituting ‘calendar 12
year 2024’ for ‘calendar year 2016’ in sub-13
paragraph (A)(ii) thereof. 14
‘‘(B) R
OUNDING.—If any amount as ad-15
justed under subparagraph (A) is not a multiple 16
of $10,000, such amount shall be rounded to 17
the next lowest multiple of $10,000. 18
‘‘(d) P
AYROLLTAX.—For purposes of this section, 19
the payroll tax for any taxable year is an amount equal 20
to the excess of— 21
‘‘(1) the taxes imposed on the taxpayer under 22
sections 1401, 1411, 3101, 3201, and 3211(a) (to 23
the extent such tax is attributable to the rate of tax 24
in effect under section 3101) with respect to such 25
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taxable year or wages or compensation received dur-1
ing such taxable year, over 2
‘‘(2) the deduction allowable under section 3
164(f) for such taxable year. 4
‘‘(e) S
PECIALRULE FORESTATES ANDTRUSTS.— 5
For purposes of this section, in the case of an estate or 6
trust, adjusted gross income shall be computed in the 7
manner described in section 67(e). 8
‘‘(f) N
OTTREATED ASTAXIMPOSED BYTHISCHAP-9
TER FORCERTAINPURPOSES.—The tax imposed under 10
this section shall not be treated as tax imposed by this 11
chapter for purposes of determining the amount of any 12
credit under this chapter (other than the credit allowed 13
under section 27(a)) or for purposes of section 55.’’. 14
(b) C
LERICALAMENDMENT.—The table of parts for 15
subchapter A of chapter 1 of the Internal Revenue Code 16
of 1986 is amended by adding at the end the following 17
new item: 18
‘‘PARTVIII—FAIRSHARETAX ONHIGH-INCOMETAXPAYERS’’.
(c) EFFECTIVEDATE.—The amendments made by 19
this section shall apply to taxable years beginning after 20
December 31, 2024. 21
SEC. 3. SENSE OF THE HOUSE REGARDING TAX REFORM. 22
It is the sense of the House of Representatives that— 23
(1) Congress should enact tax reform that re-24
peals unfair and unnecessary tax loopholes and ex-25
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penditures, simplifies the system for millions of tax-1
payers and businesses, and makes sure that the 2
wealthiest taxpayers pay a fair share; and 3
(2) this Act is an interim step that can be done 4
quickly and serve as a floor on taxes for the highest- 5
income taxpayers, cut the deficit by billions of dol-6
lars a year, and help encourage more fundamental 7
reform of the tax system. 8
Æ
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