The bill defines specified net income by expanding the definition of net investment income to
include gross income from any trade or business (unless subject to employment taxes), including interest, dividends, annuities, royalties, and rents;
include net gain from the disposition of business property;
eliminate the exclusion of income from the investment of working capital; and
eliminate the exception related to certain active partnership or S corporation interests.
The bill also
expands the net investment tax definition of a trade or business,
disallows net operating losses in calculating net investment income,
includes certain foreign-sourced income in net investment income, and
requires the IRS to issue guidance on the treatment of certain corporate distributions for purposes of the net investment tax.