The bill
To amend the Internal Revenue Code of 1986 to exclude from the value of taxable estates bequests to certain exempt organizations.
HR. 2918, 119th Congress — read as touching Private Equity & Hedge Funds.
Sponsored by
Rep. Steube, W. Gregory [R-FL-17]
ID: S001214
Follow the money
The bill
HR. 2918, 119th Congress — read as touching Private Equity & Hedge Funds.
The sponsor
Every bill has someone who introduced it. That name is where the paper trail starts.
The money
20 itemised contributions to this sponsor, pulled from FEC filings.
The alignment
This bill's text tracks the "Department of the Treasury" section, p. 730-732 of the Mandate for Leadership.
Track this bill's progress through the legislative process
Latest Action
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📍 Current Status
Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.
1. Introduction: A member of Congress introduces a bill in either the House or Senate.
2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.
3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.
4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.
5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.
6. Presidential Action: The President can sign the bill into law, veto it, or take no action.
7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!
Another masterpiece of legislative theater, courtesy of the esteemed members of Congress. Let's dissect this farce and expose the underlying disease.
**Main Purpose & Objectives:** The "Family Business Legacy Act of 2025" (HR 2918) is a cleverly crafted bill that claims to benefit family businesses by excluding bequests to certain exempt organizations from taxable estates. Sounds noble, doesn't it? But don't be fooled; this is just a thinly veiled attempt to further enrich the already wealthy and powerful.
**Key Provisions & Changes to Existing Law:** The bill amends the Internal Revenue Code of 1986 by adding a new section (2059) that allows for the exclusion of bequests to exempt organizations from taxable estates. This means that if you're a wealthy individual who wants to leave your fortune to, say, a "charitable" organization that just so happens to benefit your family business or personal interests, you can now do so without incurring estate taxes.
**Affected Parties & Stakeholders:** The primary beneficiaries of this bill are the ultra-rich and powerful individuals who have the means to establish exempt organizations that serve their own interests. These "philanthropists" will be able to pass on their wealth to future generations while avoiding taxes, further entrenching their grip on power and influence.
**Potential Impact & Implications:** This bill is a classic example of trickle-down economics, where the wealthy get to keep more of their wealth, and the rest of us are left with the crumbs. By allowing bequests to exempt organizations to be excluded from taxable estates, this bill will:
1. Increase income inequality by perpetuating the concentration of wealth among the elite. 2. Reduce government revenue from estate taxes, which could lead to decreased funding for social programs that benefit the general population. 3. Create new opportunities for tax evasion and abuse, as wealthy individuals exploit loopholes in the system.
In short, this bill is a masterclass in legislative sleight-of-hand, designed to further enrich the already powerful at the expense of everyone else. It's a symptom of a deeper disease: the corrupting influence of money in politics and the willingness of lawmakers to serve their donors rather than the public interest.
Rep. Steube, W. Gregory [R-FL-17]
Congress 119 • 2024 Election Cycle
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Hub layout: Politicians in center, donors arranged by type in rings around them.
Showing 41 nodes and 20 connections (51 secondary connections hidden)
Total contributions: $72,600
Showing top 16 donors by contribution amount
Which industries are materially affected by specific provisions in this bill. 1 helped.
Section 2(a) adds a new section to the Internal Revenue Code, allowing deductions for bequests to certain exempt organizations, which could benefit private equity and hedge funds with philanthropic arms or investments in such organizations.
This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.
AI Analysis:
"HR 2918 aligns with Project 2025's goal of reducing estate taxes by excluding bequests to certain exempt organizations from taxable estates, thereby reducing the estate tax burden and encouraging private charitable giving as an alternative to government redistribution."
— 697 — Department of the Treasury time for any purpose. This would allow the vast majority of American families to save and invest without facing a punitive double layer of taxation. Entrepreneurship. To encourage entrepreneurship, the business loss limita- tion should be increased to at least $500,000. Businesses should also be allowed to fully carry forward net operating losses. Extra layers of taxes on investment and capital should also be eliminated or reduced. The net investment income surtax and the base erosion anti-abuse tax should be eliminated. The estate and gift tax should be reduced to no higher than 20 percent, and the 2017 tax bill’s temporary increase in the exemption amount from $5.5 million to $12.9 million (adjusted for inflation) should be made permanent.21 The tax on global intangible low-taxed income should be reduced to no higher than 12.5 percent, with the 20 percent haircut on related foreign tax credits reduced or eliminated.22 All non-business tax deductions and exemptions that were temporarily sus- pended by the 2017 tax bill should be permanently repealed, including the bicycle commuting expense exclusion, non-military moving expense deductions, and the miscellaneous itemized deductions.23 The individual state and local tax deduction, which was temporarily capped at $10,000, should be fully repealed. Deductions related to educational expenses should be repealed. Special business tax pref- erences, such as a special deduction for energy-efficient commercial building properties, should be eliminated.24 Wages vs. Benefits. The current tax code has a strong bias that incentivizes businesses to offer employees more generous benefits and lower wages. This limits the freedom of workers and their families to spend their compensation as they see fit—and it can trap workers in their current jobs due to the jobs’ benefit pack- ages. Wage income is taxed under the individual income tax and under the payroll tax. However, most forms of non-wage benefits are wholly exempt from both of these taxes. To reduce this tax bias against wages (as opposed to employee benefits), the next Administration should set a meaningful cap (no higher than $12,000 per year per full-time equivalent employee—and preferably lower) on untaxed benefits that employers can claim as deductions. Employee benefit expenses other than tax-deferred retirement account contributions should count toward the limita- tion, whether offered to specific employees or whether the costs relate to a shared benefit like building gym facilities for employees.25 Tax-deferred retirement con- tributions by employers should not count toward this limitation insofar as they are fully taxable upon distribution. Only a percentage of Health Savings Accounts (HSA) contributions (which are not taxed upon withdrawal) should count toward the limitation.26 The limitation on benefit deductions should not be indexed to increase with inflation.27 Employers should also be denied deductions for health insurance and other benefits provided to employee dependents if the dependents are aged 23 or older.
AI Analysis:
"HR 2918's estate tax charitable exclusion directly supports Project 2025's objective of reducing the estate and gift tax burden and simplifying the tax code, aligning with its goal to lower estate taxes and encourage tax‑efficient wealth transfers."
— 697 — Department of the Treasury time for any purpose. This would allow the vast majority of American families to save and invest without facing a punitive double layer of taxation. Entrepreneurship. To encourage entrepreneurship, the business loss limita- tion should be increased to at least $500,000. Businesses should also be allowed to fully carry forward net operating losses. Extra layers of taxes on investment and capital should also be eliminated or reduced. The net investment income surtax and the base erosion anti-abuse tax should be eliminated. The estate and gift tax should be reduced to no higher than 20 percent, and the 2017 tax bill’s temporary increase in the exemption amount from $5.5 million to $12.9 million (adjusted for inflation) should be made permanent.21 The tax on global intangible low-taxed income should be reduced to no higher than 12.5 percent, with the 20 percent haircut on related foreign tax credits reduced or eliminated.22 All non-business tax deductions and exemptions that were temporarily sus- pended by the 2017 tax bill should be permanently repealed, including the bicycle commuting expense exclusion, non-military moving expense deductions, and the miscellaneous itemized deductions.23 The individual state and local tax deduction, which was temporarily capped at $10,000, should be fully repealed. Deductions related to educational expenses should be repealed. Special business tax pref- erences, such as a special deduction for energy-efficient commercial building properties, should be eliminated.24 Wages vs. Benefits. The current tax code has a strong bias that incentivizes businesses to offer employees more generous benefits and lower wages. This limits the freedom of workers and their families to spend their compensation as they see fit—and it can trap workers in their current jobs due to the jobs’ benefit pack- ages. Wage income is taxed under the individual income tax and under the payroll tax. However, most forms of non-wage benefits are wholly exempt from both of these taxes. To reduce this tax bias against wages (as opposed to employee benefits), the next Administration should set a meaningful cap (no higher than $12,000 per year per full-time equivalent employee—and preferably lower) on untaxed benefits that employers can claim as deductions. Employee benefit expenses other than tax-deferred retirement account contributions should count toward the limita- tion, whether offered to specific employees or whether the costs relate to a shared benefit like building gym facilities for employees.25 Tax-deferred retirement con- tributions by employers should not count toward this limitation insofar as they are fully taxable upon distribution. Only a percentage of Health Savings Accounts (HSA) contributions (which are not taxed upon withdrawal) should count toward the limitation.26 The limitation on benefit deductions should not be indexed to increase with inflation.27 Employers should also be denied deductions for health insurance and other benefits provided to employee dependents if the dependents are aged 23 or older. — 698 — Mandate for Leadership: The Conservative Promise Fundamental Tax Reform. Achieving fundamental tax reform offers the prospect of a dramatic improvement in American living standards and an equally dramatic reduction in tax compliance costs. Lobbyists, lawyers, benefit consul- tants, accountants, and tax preparers would see their incomes decline, however. The federal income tax system heavily taxes capital and corporate income and discourages work, savings, and investment. The public finance literature is clear that a consumption tax would minimize government’s distortion of private economic decisions and thus be the least eco- nomically harmful way to raise federal tax revenues.28 There are several forms that a consumption tax could take, including a national sales tax, a business transfer tax, a Hall–Rabushka flat tax,29 or a cash flow tax.30 Supermajority to Raise Taxes. Treasury should support legislation instituting a three-fifths vote threshold in the U.S. House and the Senate to raise income or corporate tax rates to create a wall of protection for the new rate structure. Many states have implemented such a supermajority vote requirement. Tax Competition. Tax competition between states and countries is a positive force for liberty and limited government.31 The Biden Administration, under the direction of Treasury Secretary Janet Yellen, has pushed for a global minimum corporate tax that would increase taxation and the size of government in the U.S. and around the world. This attempt to “harmonize” global tax rates is an attempt to create a global tax cartel to quash tax competition and to increase the tax burden globally. The U.S. should not outsource its tax policy to international organizations. Organization for Economic Co-operation and Development. The Organi- zation for Economic Co-operation and Development (OECD), in conjunction with the European Union, has long tried to end financial privacy and impose regulations on countries with low (or no) income taxes. In fact, on tax, environmental, corpo- rate governance and employment issues, the OECD has become little more than a taxpayer-funded left-wing think tank and lobbying organization.32 The United States provides about one-fifth of OECD’s funding.33 The U.S. should end its finan- cial support and withdraw from the OECD. TAX ADMINISTRATION The Internal Revenue Service is a poorly managed, utterly unresponsive and increasingly politicized agency, and has been for at least two decades. It is time for meaningful reform to improve the efficiency and fairness of tax administration, better protect taxpayer rights, and achieve greater transparency and accountability. A substantial number of the problems attributed to the IRS are actually a function of congressional action that has made the Internal Revenue Code ridiculously complex, imposed tremendous administrative burdens on both the public and the IRS, and given massive non-tax missions to the IRS. But the culture, administrative practices, and management at the IRS need to change.
AI Analysis:
"HR 2918 aligns with Project 2025's Treasury Department goals by promoting tax code reforms that reduce estate tax burdens and incentivize private charitable giving, reflecting broader conservative tax reform themes. However, the bill does not directly address core Project 2025 Treasury priorities like consumption tax shifts, corporate tax reform, or IRS restructuring, resulting in moderate rather than strong alignment."
— 712 — Mandate for Leadership: The Conservative Promise 17. For a detailed discussion, see David R. Burton, “Tax Reform: Eliminating the Double Taxation of Corporate Income,” Heritage Foundation Backgrounder No. 3216, May 18, 2017, https://www.heritage.org/sites/default/ files/2017-05/BG3216.pdf. 18. One hundred dollars in corporate income less an 18 percent tax leaves $82. A 15 percent capital gains tax or qualified dividends tax is $12.30, which leaves $69.70, for an effective marginal tax rate of 30 percent. This, of course, abstracts away from certain timing issues. 19. Inflation Reduction Act, Public Law 117–169. 20. Ibid. 21. Tax Cuts and Jobs Act, Public Law 115–97, § 11061, amending Internal Revenue Code § 2010(c). The amounts before inflation adjustments are $5 million and $10 million, respectively. See also Internal Revenue Service, “What’s New: Estate and Gift Tax, Basic Exclusion Amount for Year of Death,” https://www.irs.gov/businesses/ small-businesses-self-employed/whats-new-estate-and-gift-tax (accessed March 22, 2023). 22. The effective tax rate on foreign-derived intangible income should remain equal to the tax rate on global intangible low-taxed income. 23. For miscellaneous itemized deductions, see Internal Revenue Code (26 U.S. Code § 67). Business deductions that were suspended by the 2017 tax bill (other than those related to depreciation) should also be extended. This includes the local lodging expense deduction and entertainment expense deductions. The 2017 tax bill’s modifications to the deduction for personal casualty and theft losses should be made permanent. The Pease limitation on itemized deductions should be permanently eliminated. 24. Bonus depreciation provisions applied to specific industries should be maintained. 25. Employer-provided childcare expenses should also count toward the limitation on benefit deductions. 26. HSAs are flexible and portable, and they help contain costs by giving health care consumers skin in the game. 27. For additional revenue to fund pro-growth tax cuts, lawmakers could gradually phase down the limitation on benefit deductions. 28. Early versions of the 2017 tax bill envisioned reforming the corporate income tax into a destination-based cash flow tax, a form of consumption tax. A tax system that taxes labor and capital-factor incomes equally— and only once—results in higher output and higher incomes. Usually, in the modern public finance literature, this is called a consumption tax. On the economic superiority of consumptions taxes, see N. Gregory Mankiw et al., “Optimal Taxation in Theory and Practice,” Journal of Economic Perspectives, Vol. 23, No. 4 (2009), pp. 147–174, https://pubs.aeaweb.org/doi/pdfplus/10.1257/jep.23.4.147 (accessed March 19, 2023); Alan J. Auerbach, “The Choice Between Income and Consumption Taxes: A Primer,” NBER Working Paper No. 12307, June 2006, https://www.nber.org/system/files/working_papers/w12307/w12307.pdf (accessed March 19, 2023); and Charles E. Walker and Mark A. Bloom eld, eds., The Consumption Tax: A Better Alternative? (Cambridge, MA: Harper and Row, Ballinger, 1987). 29. Hoover Institution, “Simplifying the Tax System: The History of the Flat Tax,” March 1, 2019, https://www. hoover.org/research/simplifying-tax-system-history-flat-tax (accessed March 20, 2023). 30. David R. Burton, “Four Conservative Tax Plans with Equivalent Economic Results,” Heritage Foundation Backgrounder No. 2978, December 7, 2022, https://www.heritage.org/taxes/report/four-conservative-tax- plans-equivalent-economic-results. Consumption tax plans generally include carveouts that exempt very low-income Americans from federal tax liability. 31. Daniel J. Mitchell and Chris Edwards, Global Tax Revolution: The Rise of Tax Competition and the Battle to Defend It (Washington, DC: Cato Institute, 2008); Preston Brashers, “Like Constitutional Checks and Balances, Tax Competition Is a Bulwark Against Growth of Government,” March 17, 2022, https://www.heritage.org/ taxes/commentary/constitutional-checks-and-balances-tax-competition-bulwark-against-growth (accessed March 19, 2023). 32. James M. Robers et al., “Organization for Economic Co-operation and Development (OECD): What America Should Do,” Heritage Foundation Backgrounder No. 3593, March 16, 2021, https://www.heritage.org/ sites/default/files/2021-03/BG3593.pdf; Preston Brashers. “The OECD Crusade To Raise Taxes,” Heritage Foundation Commentary, February 4, 2022, https://www.heritage.org/taxes/commentary/the-oecd-crusade- raise-taxes; David Burton, “How the OECD is Promoting More Identity Theft, Crime, Industrial Espionage, and Suppression of Political Dissidents,” July 15, 2016, Heritage Foundation Commentary, https://www.heritage. org/taxes/commentary/how-the-oecd-promoting-more-identity-theft-crime-industrial-espionage-and; — 713 — Department of the Treasury David R. Burton “Towards a Global Tax Cartel?” Policy, Vol. 18, No. 4 (Summer 2002–2003), Center for Independent Studies (Australia), https://www.cis.org.au/wp-content/uploads/2015/04/images/stories/policy- magazine/2002-summer/2002-18-4-david-r-burton.pdf (accessed March 19, 2023). 33. Roberts et al., “Organization for Economic Co-operation and Development (OECD).” 34. See Inflation Reduction Act, § 10301. See also Preston Brashers, “IRS and Allies Downplay 87,000-Person Hiring Binge,” The Daily Signal, August 12, 2022, https://www.dailysignal.com/2022/08/12/the-irs-and-its- allies-downplay-87000-person-hiring-binge/ (accessed March 19, 2023). 35. U.S. Department of the Treasury, General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, May 2021, pp. 88–89, https://home.treasury.gov/system/files/131/General-Explanations-FY2022.pdf (accessed March 19. 2023). 36. See U.S. Department of the Treasury, Fiscal Year 2022–2026 Strategic Plan. 37. U.S. House of Representatives, Committee on Oversight and Reform, Policy and Supporting Positions, December 2020 (the “plumb book”), p. 127 https://www.govinfo.gov/content/pkg/GPO-PLUMBOOK-2020/ pdf/GPO-PLUMBOOK-2020.pdf (accessed March 19, 2023). 38. Internal Revenue Service, “Organization and Top Officials,” https://www.irs.gov/pub/newsroom/marketing/ internet/irs-organization-chart.pdf (accessed March 19, 2023). See also Internal Revenue Code (26 U.S. Code § 7803(a)–(b)). 39. For a summary of various GAO reports on various IRS IT problems, see Vijay A. D’Souza, “Information Technology: IRS Needs to Address Operational Challenges and Opportunities to Improve Management,” testimony before the Subcommittee on Government Operations, Committee on Oversight and Reform, U.S. House of Representatives, October 7, 2020, GAO–21–178T, https://www.gao.gov/assets/gao-21-178t. pdf (accessed March 19, 2023). Charles O. Rossotti was named IRS Commissioner by President Bill Clinton primarily so that Rossotti could address widely acknowledged IT issues. He made some improvements between 1997 and 2002, but despite large investments, he did not really resolve the IT problems at the IRS. Since that time, the problems have worsened. 40. D’Souza, “Information Technology,” figure 1, p. 5. 41. Internal Revenue Service, IRS Integrated Modernization Business Plan, April 2019, https://www.irs.gov/pub/ irs-pdf/p5336.pdf (accessed March 20, 2023). 42. See, for example, the Omnibus Taxpayers’ Bill of Rights, Public Law 100–647, Subtitle J of Title VI of the Technical and Miscellaneous Revenue Act of 1988; Taxpayer Bill of Rights 2, Public Law 104–168; IRS Restructuring and Reform Act of 1998, Public Law 105–206, Title III; Consolidated Appropriations Act, Public Law 114–113, Title IV, Subtitle A (adding Internal Revenue Code § 7803(a)(3) and other changes); and Taxpayer First Act, Public Law 116–25, Title I. 43. For a list of 68 proposed reforms, see National Taxpayer Advocate, 2022 Purple Book: Compilation of Legislative Recommendations to Strengthen Taxpayer Rights and Improve Tax Administration, December 31, 2021, https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2022/01/ARC21_PurpleBook.pdf (accessed March 19, 2023). Most, though not all, of these proposals have merit. Regarding penalty reform, see Jeremiah Coder, “Achieving Meaningful Civil Tax Penalty Reform and Making It Stick,” Akron Tax Journal, Vol. 27 (2012), https://ideaexchange.uakron.edu/cgi/viewcontent.cgi?article=1153&context=akrontaxjournal (accessed March 19, 2023). 44. Internal Revenue Service, 2023 Congressional Budget Justification & Annual Performance Report and Plan, Rev. 3–2022, https://home.treasury.gov/system/files/266/Internal-Revenue-Service-FY-2023-CJ.pdf (accessed March 19, 2023). 45. Internal Revenue Service, 2021 IRS Data Book: October 1, 2020 to September 30, 2021, table 11, p. 26, https:// www.irs.gov/pub/irs-pdf/p55b.pdf (accessed March 19, 2023). 46. Ibid., 2021 IRS Data Book, table 2, p. 4. 47. Scott A. Hodge, “The Compliance Costs of IRS Regulations, Tax Foundation Fiscal Fact No. 512, June 2016 https://files.taxfoundation.org/legacy/docs/TaxFoundation_FF512.pdf (accessed March 19, 2023). 48. Organization for Economic Cooperation, The Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Amended by the 2010 Protocol, https://read.oecd-ilibrary.org/taxation/the-multilateral- convention-on-mutual-administrative-assistance-in-tax-matters_9789264115606-en#page1 (accessed March 20, 2023).
Showing 3 of 5 policy matches
Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.