1. Short title This Act may be cited as the Billionaire Minimum Income Tax Act . 2. Minimum tax on certain wealthy taxpayers (a) In general Subtitle A of the Internal Revenue Code of 1986 is amended by inserting after chapter 4 the following new chapter: 5 Minimum tax on certain wealthy taxpayers Sec. 1481. Minimum tax on certain wealthy taxpayers. Sec. 1482. Certain otherwise exempt transfers by certain wealthy taxpayers treated as taxable. 1481. Minimum tax on certain wealthy taxpayers (a) In general In the case of an applicable taxpayer, there is hereby imposed (in addition to any other tax imposed by this subtitle) for each taxable year a tax equal to the excess (if any) of— (1) 25 percent of the sum of— (A) the taxpayer’s taxable income for such taxable year, plus (B) the taxpayer’s net unrealized gain for such taxable year, over (2) the sum of— (A) the taxpayer’s minimum tax account balance for such taxable year, plus (B) the taxpayer’s regular tax liability (as defined in section 26(b)) for such taxable year. (b) Limitation on minimum tax The tax imposed under subsection (a) with respect to any applicable taxpayer (other than an applicable taxpayer described in subsection (c)(1)(B)) for any taxable year shall not exceed 40 percent of the excess described in subsection (c)(1)(A) with respect to such taxpayer for such taxable year. (c) Applicable taxpayer For purposes of this section— (1) In general The term applicable taxpayer means— (A) any individual for any taxable year if the taxpayer’s net worth for such taxable year exceeds $100,000,000 (half such amount in the case of a married individual filing a separate return), and (B) any trust or estate treated as an applicable taxpayer under subsection (g). (2) Net worth The term net worth means, with respect to any taxpayer for any taxable year, the excess (if any), determined as of the close of such taxable year, of— (A) the estimated value of all assets of the taxpayer and all trust attributed assets of the taxpayer, as determined under regulations