To amend the Internal Revenue Code of 1986 to impose limitations on high-income taxpayers with large retirement account balances.

This bill amends the Internal Revenue Code to impose contribution limits and increased minimum required distributions on high-income taxpayers with large retirement account balances.

Sec. 1, Contribution limit for individual retirement plans of high-income taxpayers with large account balances: For taxable years after 2026, an "applicable taxpayer" (with modified adjusted gross income over $450,000 for joint filers, $425,000 for head of household, $225,000 for married filing separately, or $400,000 otherwise) cannot make annual contributions to an individual retirement plan (IRA) that exceed the excess of $10,000,000 (adjusted for inflation after 2027) over the taxpayer's aggregate vested balances in all applicable retirement plans (including 401(a), 403(a), 403(b), 457(b), and IRAs). Employer/employee contributions to SEP and SIMPLE plans reduce this limit but are not treated as contributions subject to the limit. Rollovers, and accounts acquired by death or divorce, are not counted as contributions. An excise tax is imposed on excess contributions.

Sec. 2, Increase in minimum required distributions for high-income taxpayers with large retirement account balances: For taxable years beginning after 2033, if an applicable taxpayer's aggregate vested balances in all applicable retirement plans exceed the applicable dollar amount ($10,000,000, adjusted for inflation), the minimum required distributions from those plans are increased. The increase is 50% of the excess over the applicable dollar amount, plus an additional amount if balances exceed 200% of the applicable dollar amount (the "applicable Roth excess amount"). The taxpayer may allocate the increase among plans, but Roth IRAs and designated Roth accounts must be distributed first for the Roth excess amount. Distributions under this section are not eligible for rollover and are treated as qualified distributions from Roth accounts. Plans must allow affected employees to elect immediate distributions. The 10% early distribution tax does not apply to these distributions. Withholding on such distributions is 37% (unless from a designated Roth account).