Ending the Carried Interest Loophole Act

[Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [S. 4330 Introduced in Senate (IS)] <DOC> 119th CONGRESS 2d Session S. 4330 To amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes. _______________________________________________________________________ IN THE SENATE OF THE UNITED STATES April 16 (legislative day, April 14), 2026 Mr. Wyden (for himself, Mr. Whitehouse, Mr. King, Ms. Warren, Mr. Sanders, Ms. Smith, Mr. Lujan, Mr. Schatz, Mr. Reed, Ms. Hirono, Mr. Markey, Mr. Fetterman, Mr. Blumenthal, and Mr. Van Hollen) introduced the following bill; which was read twice and referred to the Committee on Finance _______________________________________________________________________ A BILL To amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the ``Ending the Carried Interest Loophole Act''. SEC. 2. PARTNERSHIP INTERESTS TRANSFERRED IN CONNECTION WITH PERFORMANCE OF SERVICES. (a) Modification of Election To Include Partnership Interest in Gross Income in Year of Transfer.--Subsection (c) of section 83 is amended by redesignating paragraph (4) as paragraph (5) and by inserting after paragraph (3) the following new paragraph: ``(4) Partnership interests.--Except as provided by the Secretary-- ``(A) In general.--In the case of any transfer of an interest in a partnership in connection with the performance of services-- ``(i) the fair market value of such interest shall be treated for purposes of this section as being equal to the amount which the partner would receive if the partnership sold (at the time of the transfer) all of its assets for cash a