What does Preamble of S 3930 do?

This bill, formally titled 'To amend the Internal Revenue Code of 1986 to impose an excise tax on the acquisition of single-family residences by hedge fund taxpayers, and for other purposes,' aims to modify the Internal Revenue Code of 1986. The bill proposes to impose an excise tax specifically on the acquisition of single-family residences by hedge fund taxpayers.

What does SHORT TITLE. of S 3930 do?

This bill is formally titled the HOPE (Humans over Private Equity) for Homeownership Act.

What does EXCISE TAX ON ACQUISITION OF SINGLE-FAMILY RESIDENCES BY HEDGE of S 3930 do?

This section amends the Internal Revenue Code of 1986 by adding Chapter 50B, titled 'Single-Family Residences'. It imposes a 15 percent excise tax on the acquisition of newly acquired single-family residences by hedge fund taxpayers. A 'newly acquired single-family residence' is defined as a property with 1-to-4 dwelling units acquired after the chapter's enactment. An exception exists if the property is not rented or leased and is used as the principal residence of someone with an ownership interest in the hedge fund. A 'hedge fund taxpayer' is an applicable entity managing pooled funds with $50,000,000 or more in net value, acting as a fiduciary. Applicable entities include partnerships, corporations, and real estate investment trusts, with exceptions for 501(c)(3) organizations and those primarily engaged in single-family residence construction/rehabilitation. The 'purchase price' is defined as the adjusted basis of the residence on the date of purchase. A taxpayer is considered to acquire a single-family residence if they acquire a majority ownership interest. The amendments apply to taxable years beginning after the date of enactment of this Act.

What does CORPORATE SURTAX ON HEDGE FUND TAXPAYERS. of S 3930 do?

This section amends Section 11 of the Internal Revenue Code of 1986. The amendment introduces a new subsection (e) regarding 'Hedge Fund Taxpayers'. For corporations described in section 5000E(c), the percentage under subsection (b) is increased by 5 percentage points. The amendment applies to taxable years beginning after December 31, 2035.

What does DISALLOWANCE OF CERTAIN DEDUCTIONS TAKEN IN CONNECTION WITH of S 3930 do?

This section amends the Internal Revenue Code of 1986 to disallow mortgage interest deductions for certain hedge fund taxpayers with respect to single-family residences. It also disallows depreciation deductions for hedge fund taxpayers for single-family residences. The term 'hedge fund taxpayer' is defined as a taxpayer described in section 5000E(c) who is in the trade or business of renting or leasing single-family residences. The definition of 'single-family residence' is established as any residential property with 1-to-4 dwelling units. The amendments related to mortgage interest apply to taxable years beginning after December 31, 2030. The amendments related to depreciation apply to taxable years beginning after December 31, 2030. The amendments related to Qualified Business Income apply to taxable years beginning after December 31, 2035.

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HOPE (Humans over Private Equity) for Homeownership Act — S. 3930

Last updated: 2/26/2026 · Introduced: 2/26/2026

Author: Jeff Merkley (D-OR)

TL;DR (AI)

This bill imposes a 15% excise tax on hedge funds acquiring single-family residences, with an exception for properties used as the principal residence of someone with an ownership interest in the fund.
The bill increases the corporate surtax by 5 percentage points for certain hedge fund taxpayers, starting after 2035.
Hedge fund taxpayers engaged in renting or leasing single-family residences will be disallowed mortgage interest and depreciation deductions, starting after 2030.

119th Congressin committeeOfficial page

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Includes provisions on preamble, short title., and 3 more.

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