A bill 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 distribution requirements on high-income taxpayers with large retirement account balances.

Sec. 1, Contribution limit for high-income taxpayers with large account balances: For taxable years after 2026, an "applicable taxpayer" (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 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. Employer/employee SEP and SIMPLE contributions reduce this limit. Rollovers, death, divorce, or separation transfers are not counted. Excess contributions are subject to an excise tax.

Sec. 2, Increase in minimum required distributions for high-income taxpayers with large account balances: For taxable years 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 distribution is 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, with Roth IRAs and designated Roth accounts receiving the Roth excess amount first. Plans must allow immediate distribution upon certification. Distributions under this section are exempt from the 10% early distribution tax and are subject to 37% withholding (unless from a designated Roth account).