H.R. 1091 (119th)Bill Overview

Carried Interest Fairness Act of 2025

Taxation|Taxation
Cosponsors
Support
Democratic
Introduced
Feb 6, 2025
Discussions
Bill Text
Current stageCommittee

Referred to the House Committee on Ways and Means.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief
Plain-English summaryWhat this bill actually does

This bill amends the Internal Revenue Code to change how partnership interests received for personal services—commonly called "carried interests"—are taxed. It recharacterizes long-term capital gains and certain allocations tied to investment services partnership interests as ordinary income, treats dispositions and many distributions as ordinary, tightens valuation and reporting, increases penalties for avoidance, and requires such income to be included in self-employment earnings.

Why people may split

Progressives emphasize fairness and revenue; conservatives emphasize tax increases and economic harm.

Watch point

Relative to its intended legislative type, this bill is a detailed substantive tax-policy enactment that specifies comprehensive statutory mechanisms, implementation timing, cross-statutory integration, and anti-avoidance measures while leaving regulatory detail and administrative implementation to the Secretary of the Treasury.

This bill amends the Internal Revenue Code to change how partnership interests received for personal services—commonly called "carried interests"—are taxed.

It recharacterizes long-term capital gains and certain allocations tied to investment services partnership interests as ordinary income, treats dispositions and many distributions as ordinary, tightens valuation and reporting, increases penalties for avoidance, and requires such income to be included in self-employment earnings.

The bill defines "investment services partnership interest," creates exceptions for qualified capital interests and certain corporations, and adds regulatory and anti-abuse authority for the Treasury Secretary.

Passage18/100

Technically complex and ideologically charged tax overhaul affecting powerful economic interests; limited built‑in coalition signals despite some carve‑outs.

CredibilityAligned

Relative to its intended legislative type, this bill is a detailed substantive tax-policy enactment that specifies comprehensive statutory mechanisms, implementation timing, cross-statutory integration, and anti-avoidance measures while leaving regulatory detail and administrative implementation to the Secretary of the Treasury.

Contention75/100

Progressives emphasize fairness and revenue; conservatives emphasize tax increases and economic harm.

02 · What it does

Who stands to gain, and who may push back.

Likely benefits vs burdens50% / 50%
Federal agenciesLikely burdened

These are examples from the analysis, not a ranked list of the most-affected groups.

Likely helped
  • Federal agenciesRaises federal revenue by taxing carried interest as ordinary income rather than capital gains.
  • Potential benefitReduces opportunities for tax arbitrage by aligning treatment of service-originated partnership gains with ordinary com…
  • Potential benefitExtends payroll tax base by treating investment services partnership income as self-employment earnings.
Likely burdened
  • Potential burdenIncreases tax liabilities for fund managers, partners, and carried-interest recipients.
  • Potential burdenRaises compliance and administrative costs for partnerships due to valuation and reporting obligations.
  • Potential burdenMay incentivize changes in compensation or organizational form, shifting activity to C corporations or other vehicles.
03 · Why people split

Why the argument around this bill splits.

Progressives emphasize fairness and revenue; conservatives emphasize tax increases and economic harm.
Progressive90%

This persona is likely to view the bill favorably as closing a long-standing tax preference for investment managers, treating labor-like carried interest income as ordinary.

They will see it as improving tax fairness and potentially increasing federal revenue for public programs.

Some caution remains about complexity and ensuring small advisers or family partnerships are not unfairly hit.

Leans supportive
Centrist60%

A pragmatic centrist will see merits in removing a tax mismatch where returns for service are taxed as capital gains, but will worry about administrative complexity and economic side effects.

They will weigh revenue and fairness benefits against implementation costs, compliance burdens, and possible impacts on investment markets.

Support is conditional on narrow, well-defined rules and careful transitional guidance.

Split reaction
Conservative15%

This persona is likely to oppose the bill as an overreach that raises taxes on investment professionals and expands IRS authority.

They will view recharacterizing long-term capital gains as ordinary income and higher penalties as anti-business, potentially harming capital formation and partnership flexibility.

They will also object to increased self-employment taxation and broadened enforcement discretion.

Likely resistant
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood18/100

Technically complex and ideologically charged tax overhaul affecting powerful economic interests; limited built‑in coalition signals despite some carve‑outs.

Scope and complexity
52%
Scopemoderate
86%
Complexityhigh
Why this could stall
  • Absent official revenue score and budget offsets
  • Intensity and effectiveness of industry lobbying
05 · Recent votes

Recent votes on the bill.

No vote history yet

The bill has not accumulated any surfaced votes yet.

06 · Go deeper

Go deeper than the headline read.

Included on this page

Progressives emphasize fairness and revenue; conservatives emphasize tax increases and economic harm.

Technically complex and ideologically charged tax overhaul affecting powerful economic interests; limited built‑in coalition signals despit…

Unlocked analysis

Relative to its intended legislative type, this bill is a detailed substantive tax-policy enactment that specifies comprehensive statutory mechanisms, implementation timing, cross-statutory integration, and anti-avoidan…

Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.

Perspective breakdownsPassage barriersLegislative design reviewStakeholder impact map
Open full analysis