(a) In general

Subchapter H of chapter 42 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section:

4969. Excise tax on certain large private college and university endowments

(a) Tax imposed

There is hereby imposed on each specified applicable educational institution for the institution's first taxable year beginning in 2025 a tax equal to 6 percent of the aggregate fair market value of the assets of the institution at the end of the preceding taxable year.

(b) Specified applicable educational institution

For purposes of this subchapter, with respect to a taxable year, the term specified applicable educational institution means—

(1)

any applicable educational institution, other than an institution which is religious in nature, the aggregate fair market value of the assets of which at the end of the preceding taxable year (other than those assets which are used directly in carrying out the institution's exempt purpose) is at least $11,900,000,000, and

(2)

any applicable educational institution—

(A)

which operates a college on behalf of a State pursuant to State statute or contractual agreements, and

(B)

the aggregate fair market value of the assets of which at the end of the preceding taxable year (other than those assets which are used directly in carrying out the institution's exempt purpose) is at least $10,500,000,000.

(c) Other terms

For purposes of this section—

(1) Assets

The rules of section 4968(d) shall apply.

(2) Student

The rules of section 4968(b)(2) shall apply.

(b) Clerical amendment

The table of sections for subchapter H of chapter 42 of the Internal Revenue Code of 1986 is amended by adding at the end the following new item:

(c) Effective date

The amendments made by this section shall apply to taxable years beginning after December 31, 2024.