; table of contents. Sec. 2. Purpose. TITLE I—Elimination of deferral for applicable taxpayers Sec. 101. Elimination of deferral of tax. Sec. 102. Carryback of capital losses attributable to mark-to-market rules. TITLE II—Application of other provisions to applicable taxpayers and entities Subtitle A—Individuals Sec. 201. Applicable taxpayers not eligible for adjusted gross income limitation on net investment tax. Sec. 202. Treatment of covered expatriates. Subtitle B—Rules for applicable entities and trusts Sec. 211. Treatment of like-kind exchanges by applicable entities. Sec. 212. Treatment of transfers by applicable entities in exchange for stock. Sec. 213. Special rules for applicable trusts. Subtitle C—Treatment of deferred compensation and certain life insurance and annuity contracts Sec. 221. Elimination of deferral of tax on certain compensation. Sec. 222. Rules relating to certain life insurance and annuity contracts of applicable taxpayers. Subtitle D—Repeal of special treatment for certain investments Sec. 231. Treatment of exclusion for certain small business stock. Sec. 232. Modifications for investments in qualified opportunity funds. 2. Purpose The purpose of this Act is to require billionaires to pay taxes annually by eliminating the ability of high income and high net worth taxpayers to use tax planning strategies such as buy, borrow, die to defer paying taxes indefinitely, specifically by— (1) under the provisions of title I of this Act— (A) requiring high income and high net worth taxpayers to pay tax on the income they earn on an annual basis, just like working people do on their income from wages, through mark-to-market taxation, and (B) shutting down the ability of the ultra wealthy to buy and hold appreciating assets and borrow against those assets to support their lavish lifestyles, all completely tax-free, and (2) under the provisions of title II of this Act, closing loopholes in the tax code that allow high income and high net worth taxpayers to shield their income from taxation,