Applicable taxpayers not eligible for adjusted gross income limitation on net investment tax

(a) In general Section 1411(a) is amended by adding at the end the following new paragraph: (3) No adjusted gross income limit for applicable taxpayers In the case of an applicable taxpayer (as defined in section 495) for any taxable year, notwithstanding paragraph (1) or (2), the tax under this subsection for such taxable year shall be equal to the product of— (A) in the case of an individual, the rate of tax in effect under paragraph (1) multiplied by the amount determined under paragraph (1)(A), and (B) in the case of an estate or trust, the rate of tax in effect under paragraph (2) multiplied by the amount determined under paragraph (2)(A).. (b) Effective date The amendment made by this section shall apply to taxable years beginning after December 31, 2025.