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

This section imposes a 15% excise tax on a hedge fund taxpayer's acquisition of any newly acquired single-family residence (i.e., residential property with 1-to-4 dwelling units acquired in taxable years beginning after enactment). A hedge fund taxpayer is an applicable entity (i.e., partnership, corporation, or real estate investment trust, excluding 501(c)(3) organizations and certain home builders) that manages pooled investor funds, has $50 million or more in assets under management on any day in the taxable year, and acts as a fiduciary to those investors (with aggregation rules treating related entities as a single taxpayer). The tax does not apply if the property is used as the principal residence of a person with an ownership interest in the acquiring taxpayer and is not rented or leased; acquisition occurs upon obtaining a majority ownership interest, and the tax base is the property's adjusted basis on the purchase date. The provision applies to taxable years beginning after enactment.

This section increases the corporate income tax rate by 5 percentage points for hedge fund taxpayers (i.e., corporations described in section 5000E(c)), to 26% (from 21%), for taxable years beginning after December 31, 2035.

This section disallows, for hedge fund taxpayers (i.e., taxpayers described in IRC §5000E(c) who are in the trade or business of renting or leasing single-family residences), three tax benefits related to single-family residences (i.e., residential properties consisting of 1-to-4 dwelling units): (1) the deduction for interest on acquisition indebtedness under IRC §163, for taxable years beginning after December 31, 2030; (2) the depreciation deduction under IRC §167, for taxable years beginning after December 31, 2030; and (3) the qualified business income (QBI) deduction under IRC §199A for such trade or business, for taxable years beginning after December 31, 2035.