1. Short title This Act may be cited as the American Neighborhoods Protection Act of 2023 . 2. Excise tax on certain taxpayers failing to sell excess single-family residences (a) In general Subtitle D of the Internal Revenue Code of 1986 is amended by adding at the end the following new chapter: 50B Excess Single-Family Residences Sec. 5000E. Excess single-family residences. 5000E. Excess single-family residences (a) In general There is hereby imposed on each covered taxpayer for each taxable year a tax in an amount equal to the product of— (1) $10,000, and (2) the excess of— (A) the number of single-family residences owned by the taxpayer as of the last day of the taxable year, over (B) 75. (b) Covered taxpayer For purposes of this section— (1) In general The term covered taxpayer means a taxpayer that is not— (A) a mortgage note holder that owns a single-family residence through foreclosure, (B) a organization which is described in subsection 501(c)(3) and exempt from tax under section 501(a), (C) a person primarily engaged in the construction or rehabilitation of single-family residences, or (D) a person who owns federally subsidized housing. (2) Aggregation rules (A) In general For purposes of this section, all persons which are treated as a single employer under subsections (a) and (b) of section 52 shall be treated as a single taxpayer. (B) Modifications For purposes of this paragraph— (i) section 52(a) shall be applied by substituting component members for members , and (ii) for purposes of applying subsection (b), the term trade or business shall include any activity treated as a trade or business under paragraph (5) or (6) of subsection (c) (determined without regard to the phrase to the extent provided in regulations in such paragraph (6)). (C) Component member For purposes of this paragraph, the term component member has the meaning given such term by section 1563(b), except that the determination shall be made without regard to subsection (b)(2). (c) Other rules and definitions For purposes of this