United States 119th Congress Status: In Committee Bipartisan · 5 D · 2 I cosponsors

S 788 — HOPE (Humans over Private Equity) for Homeownership Act

Last action — Read twice and referred to the Committee on Finance.

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  1. ✓
    Introduced
  2. 2
    In Committee
  3. 3
    Passed Senate
  4. 4
    Passed House
  5. 5
    To Executive
  6. 6
    Enacted

This bill is in committee in the Senate. Introduced February 27, 2025. It must pass committee before a floor vote.

Next likely step: a committee vote, then a floor vote in the Senate.

Prognosis

Advancing 42% · moderate confidence

Where this bill stands today.

Odds of enactment

Low

How often bills like it became law.

  • In Committee

    Current position in the legislative process.

  • 7 sponsors

    1 primary, 6 co-sponsors signed on.

  • Bipartisan support

    Sponsored across 2 parties (5 D · 2 I) — cross-party backing.

Prognosis reads this bill's own signals — stage, sponsorship breadth, committee status, recorded votes and cross-state momentum. Odds come from a model trained on which bills have become law.

Bill Text

Sections of law this bill changes

2 sections in 1 law

From the bill's own amending language, matched to the official United States Code (current through Public Law 119-121).

Normal taxes and surtaxes · 26 U.S.C. ch. 1 2 sections
  • § 163 Interest Amends

    26 U.S.C. § 163

    The law today

    (a) General rule There shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness. (b) Installment purchases where interest charge is not separately stated (1) General rule If personal property or educational services are purchased under a contract— (A) which provides that payment of part or all of the purchase price is to be made in installments, and (B) in which carrying charges are separately stated but the interest charge cannot be ascertained, then the payments made during the taxable year under the contract shall be treated for purposes of this section as if they included interest equal to 6 percent of the average unpaid balance under the contract during the taxable year. For purposes of the preceding sentence, the average unpaid balance is the sum of the unpaid balance outstanding on the first day of each month beginning during the taxable year, divided by 12. For purposes of this paragraph, the term “educational services” means any service (including lodging) which is purchased from an educational organization described in section 170(b)(1)(A)(ii) and which is provided for a student of such organization. (2) Limitation In the case of any contract to which paragraph (1) applies, the amount treated as interest for any taxable year shall not exceed the aggregate carrying charges which are properly attributable to such taxable year. (c) Redeemable ground rents For purposes of this subtitle, any annual or periodic rental under a redeemable ground rent (excluding amounts in redemption thereof) shall be treated as interest on an indebtedness secured by a mortgage. (d) Limitation on investment interest (1) In general In the case of a taxpayer other than a corporation, the amount allowed as a deduction under this chapter for investment interest for any taxable year shall not exceed the net investment income of the taxpayer for the taxable year. (2) Carryforward of disallowed interest The amount not allowed as a deduction for any taxable year by reason of paragraph (1) shall be treated as investment interest paid or accrued by the taxpayer in the succeeding taxable year. (3) Investment interest For purposes of this subsection— (A) In general The term “investment interest” means any interest allowable as a deduction under this chapter (determined without regard to paragraph (1)) which is paid or accrued on indebtedness properly allocable to property held for investment. (B) Exceptions The term “investment interest” shall not include— (i) any qualified residence interest (as defined in subsection (h)(3)), or (ii) any interest which is taken into account under section 469 in computing income or loss from a passive activity of the taxpayer. (C) Personal property used in short sale For purposes of this paragraph, the term “interest” includes any amount allowable as a deduction in connection with personal property used in a short sale. (4) Net investment income For purposes of this subsection— (A) In general The term “net investment income” means the excess of— (i) investment income, over (ii) investment expenses. (B) Investment income The term “investment income” means the sum of— (i) gross income from property held for investment (other than any gain taken into account under clause (ii)(I)), (ii) the excess (if any) of— (I) the net gain attributable to the disposition of property held for investment, over (II) the net capital gain determined by only taking into account gains and losses from dispositions of property held for investment, plus (iii) so much of the net capital gain referred to in clause (ii)(II) (or, if lesser, the net gain referred to in clause (ii)(I)) as the taxpayer elects to take into account under this clause. Such term shall include qualified dividend income (as defined in section 1(h)(11)(B)) only to the extent the taxpayer elects to treat such income as investment income for purposes of this subsection. (C) Investment expenses The term “investment expenses” means the...

    74 other bills also change this section · Follow it → Official text at uscode.house.gov ↗

  • § 167 Depreciation Amends

    26 U.S.C. § 167

    The law today

    (a) General rule There shall be allowed as a depreciation deduction a reasonable allowance for the exhaustion, wear and tear (including a reasonable allowance for obsolescence)— (1) of property used in the trade or business, or (2) of property held for the production of income. (b) Cross reference For determination of depreciation deduction in case of property to which section 168 applies, see section 168. (c) Basis for depreciation (1) In general The basis on which exhaustion, wear and tear, and obsolescence are to be allowed in respect of any property shall be the adjusted basis provided in section 1011, for the purpose of determining the gain on the sale or other disposition of such property. (2) Special rule for property subject to lease If any property is acquired subject to a lease— (A) no portion of the adjusted basis shall be allocated to the leasehold interest, and (B) the entire adjusted basis shall be taken into account in determining the depreciation deduction (if any) with respect to the property subject to the lease. (d) Life tenants and beneficiaries of trusts and estates In the case of property held by one person for life with remainder to another person, the deduction shall be computed as if the life tenant were the absolute owner of the property and shall be allowed to the life tenant. In the case of property held in trust, the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each. In the case of an estate, the allowable deduction shall be apportioned between the estate and the heirs, legatees, and devisees on the basis of the income of the estate allocable to each. (e) Certain term interests not depreciable (1) In general No depreciation deduction shall be allowed under this section (and no depreciation or amortization deduction shall be allowed under any other provision of this subtitle) to the taxpayer for any term interest in property for any period during which the remainder interest in such property is held (directly or indirectly) by a related person. (2) Coordination with other provisions (A) Section 273 This subsection shall not apply to any term interest to which section 273 applies. (B) Section 305(e) This subsection shall not apply to the holder of the dividend rights which were separated from any stripped preferred stock to which section 305(e)(1) applies. (3) Basis adjustments If, but for this subsection, a depreciation or amortization deduction would be allowable to the taxpayer with respect to any term interest in property— (A) the taxpayer’s basis in such property shall be reduced by any depreciation or amortization deductions disallowed under this subsection, and (B) the basis of the remainder interest in such property shall be increased by the amount of such disallowed deductions (properly adjusted for any depreciation deductions allowable under subsection (d) to the taxpayer). (4) Special rules (A) Denial of increase in basis of remainderman No increase in the basis of the remainder interest shall be made under paragraph (3)(B) for any disallowed deductions attributable to periods during which the term interest was held— (i) by an organization exempt from tax under this subtitle, or (ii) by a nonresident alien individual or foreign corporation but only if income from the term interest is not effectively connected with the conduct of a trade or business in the United States. (B) Coordination with subsection (d) If, but for this subsection, a depreciation or amortization deduction would be allowable to any person with respect to any term interest in property, the principles of subsection (d) shall apply to such person with respect to such term interest. (5) Definitions For purposes of this subsection— (A) Term interest in property The term “term interest in property” has the meaning g...

    26 other bills also change this section · Follow it → Official text at uscode.house.gov ↗

How this bill changes current law

7 changes Share ↗

AI-generated reading aid from the bill's amendatory text — verify against the official bill.

The bill establishes an excise tax for hedge funds that fail to sell excess single-family residences.

  • Subtitle D of the Internal Revenue Code of 1986

    `CHAPTER 50B--EXCESS SINGLE-FAMILY RESIDENCES `Sec. 5000E. Newly acquired single-family residences. `Sec. 5000F. Excess single-family residences. `Sec. 5000G. Definitions and other special rules.

    A new chapter addressing the taxation of excess single-family residences owned by hedge funds is added.

  • Section 5000E

    `(a) In General.--In the case of a hedge fund taxpayer, there is hereby imposed a tax on the acquisition of any newly acquired single-family residence equal to the greater of-- `(1) 15 percent of the purchase price, or `(2) $10,000.

    An excise tax is imposed on hedge funds acquiring newly purchased single-family residences.

  • Section 5000F

    `(a) In General.--In the case of an applicable taxpayer who fails to meet the requirements of subsection (b), there is hereby imposed a tax equal to the product of-- `(1) $5,000, and `(2) the excess of-- `(A) the number of applicable single-family residences owned by the taxpayer as of the last day of the taxable year, over `(B) the maximum permissible units for the taxable year.

    An excise tax is imposed on applicable taxpayers who own more single-family residences than permitted.

  • Section 5000F(b)

    `(1) In general.--An applicable taxpayer meets the requirement of this subsection for any taxable year if the number of applicable single-family residences owned by the taxpayer as of the last day of the taxable year is equal to or less than the maximum permissible units determined with respect to such taxpayer for such taxable year.

    Defines the threshold for applicable taxpayers concerning their ownership of single-family residences.

  • Section 5000G

    `(a) Applicable Taxpayer.--For purposes of this chapter-- `(1) In general.--The term `applicable taxpayer' means any applicable entity which-- `(A) manages funds pooled from investors, and `(B) is a fiduciary with respect to such investors.

    Establishes a definition for what constitutes an 'applicable taxpayer' under the new chapter.

  • Section 5000G(c)

    `(1) In general.--The term `single-family residence' means a residential property consisting of 1- to 4 dwelling units.

    Defines a 'single-family residence' for the purpose of the new tax provisions.

  • Clerical Amendment

    `CHAPTER 50B--EXCESS SINGLE-FAMILY RESIDENCES`

    Updates the chapter table in the Internal Revenue Code to include the new chapter on excess single-family residences.

Action History

  1. Introduced in Senate

  2. Read twice and referred to the Committee on Finance.

Sponsors

Sponsorship breakdown

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1 sponsors · 6 co-sponsors · 540 not signed on

Sponsors (1)

Co-sponsors (6)

Not signed on (540)

540 members have not signed on to this bill.

Show all 540 →

"Not signed on" means a member has not sponsored or co-sponsored this bill — it does not imply opposition. Members flagged Voted No have a recorded No vote on this bill.

Whip count is in markup. Polling the chamber and every recorded vote this session. Only the first open is slow. It’s instant for you after this. Calling the roll · Tallying · Engrossing

Subjects

taxation housing
Cross-referencing the record. Reading this bill against every other bill in the corpus by meaning, not keywords. Only the first open is slow. It’s instant for you after this. Matching · Ranking · Engrossing

Frequently asked questions

Who sponsors S 788?
S 788 is sponsored by Merkley, Jeff (Democratic), King, Angus S., Jr. (Independent), Van Hollen, Chris (Democratic), Gallego, Ruben (Democratic), Sanders, Bernard (Independent), Kelly, Mark (Democratic), and Heinrich, Martin (Democratic).
What is the current status of S 788?
This bill is in committee in the Senate. Introduced February 27, 2025. It must pass committee before a floor vote.
Where can I track S 788?
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