Description of Proposed Provision:
F10: Expand the tax on net investment income (NII) as defined in the Affordable Care Act (ACA) to cover earnings from active S corporation holders and active limited partners. Apply a 12.4-percent tax on this expanded definition of NII, payable to the OASI and DI Trust Funds with specified thresholds, effective for 2025 and later. The unindexed thresholds for this provision are $400,000 for a single filer and $500,000 for a married couple filing jointly. The NII tax would apply to the lesser of NII and the excess of modified adjusted income (MAGI) above the unindexed thresholds.