This bill introduces new excise taxes and disallows certain deductions to discourage large investment entities from owning numerous single-family residences. It establishes a new chapter in the Internal Revenue Code for these provisions. A tax is imposed on "hedge fund taxpayers" (entities with $50 million+ in assets) for each newly acquired single-family residence . This acquisition tax is the greater of 15 percent of the purchase price or $10,000. Additionally, an annual excise tax of $5,000 is levied for each "excess single-family residence" owned by an "applicable taxpayer." Applicable taxpayers are entities managing pooled investor funds, including partnerships, corporations, and REITs, with specific exceptions. The number of maximum permissible units an entity can own is gradually reduced over nine years. For hedge fund taxpayers, this limit decreases to zero, while for other applicable taxpayers, it reduces to 50 units. Residences transferred in a "disqualified sale" to another business or an individual already owning a home still count towards the limit. Finally, the bill disallows deductions for mortgage interest on acquisition indebtedness and for depreciation of single-family residences if the owner is liable for the annual excess residence tax. These amendments apply to taxable years beginning after the date of enactment.
This bill introduces new excise taxes and disallows certain deductions to discourage large investment entities from owning numerous single-family residences. It establishes a new chapter in the Internal Revenue Code for these provisions. A tax is imposed on "hedge fund taxpayers" (entities with $50 million+ in assets) for each newly acquired single-family residence . This acquisition tax is the greater of 15 percent of the purchase price or $10,000. Additionally, an annual excise tax of $5,000 is levied for each "excess single-family residence" owned by an "applicable taxpayer." Applicable taxpayers are entities managing pooled investor funds, including partnerships, corporations, and REITs, with specific exceptions. The number of maximum permissible units an entity can own is gradually reduced over nine years. For hedge fund taxpayers, this limit decreases to zero, while for other applicable taxpayers, it reduces to 50 units. Residences transferred in a "disqualified sale" to another business or an individual already owning a home still count towards the limit. Finally, the bill disallows deductions for mortgage interest on acquisition indebtedness and for depreciation of single-family residences if the owner is liable for the annual excess residence tax. These amendments apply to taxable years beginning after the date of enactment.