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Supply Fund to provide affordable housing grants to state housing finance agencies.
HOUSING CHOICE VOUCHERS
Biden is calling for $32.1 billion in additional voucher funding to provide support to 200,000 additional households in need.
MARGINAL INCOME TAX RATES
The budget would increase the top statutory marginal income tax rate to 39.6 percent from 37 percent effective for taxable years beginning after December 31, 2022. Absent legislation, today’s 37 percent rate reverts to 39.6 percent beginning in 2026 under current law.
CAPITAL GAINS TAX RATES AND TAXATION OF UNREALIZED GAINS AT DEATH
The budget proposes to tax capital gains at ordinary income tax rates for taxpayers earning over $1 million. This would mean that today’s 20 percent top statutory rate would rise to 39.6 percent for impacted taxpayers not including the application of the 3.8 percent net investment income tax.
In addition, the proposal would impose a tax on unrealized capital gains at death. Taxpayers would be allowed to exclude $5 million in assets ($10 million per couple) in addition to $250,000 (single taxpayers) / $500,000 (married taxpayers) of the value of a principal residence. A 15-year fixed payment plan would be available with respect to assets other than liquid assets and taxation of unrealized gains on family-owned businesses could be deferred until the business is sold or no longer family operated.
CARRIED INTEREST
The budget proposes to tax carried interest at ordinary income tax rates as opposed to capital gains tax rates if a taxpayer’s income exceeds $400,000.
Minimum Tax on Certain Taxpayers
The budget would impose a 20 percent tax on total income, including unrealized capital gains, for taxpayers with net assets exceeding $100 million. Key features of the proposal would:
• Enable taxpayers to pay their first-year liability in nine annual installments. Liabilities in subsequent years could be paid in five annual installments. Illiquid taxpayers (i.e., taxpayers with tradeable assets that comprise less than 20 percent of wealth) could elect to defer tax on unrealized gains of tradeable assets subject to an interest charge of up to 10 percent.
• Payments would be creditable against the taxation of realized capital gains.
• Refunds would be available in the case that prepayments of the tax exceed the long- term capital gains rate times the taxpayer’s unrealized gains.
• Taxpayers with wealth exceeding $100 million would have to make annual disclosures to the Internal Revenue Service regarding their assets. Tradeable assets (e.g., publicly traded stock) would be valued end of year. Non-tradeable assets would be “valued using the greater of the original or adjusted cost basis, the last valuation event from investment, borrowing, or financial statements, or other methods approved by the Secretary.” Taxpayers would not have to obtain a valuation each year and “would instead increase by a conservative floating annual return (the five-year Treasury rate plus two percentage points) in between valuations.”
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