Add passive partnership/S-corp income input to the NIIT base - #9306
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This was referenced Aug 19, 2026
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Data-side population tracked in PolicyEngine/microcosm#722 (assignment stage: SCF non-actively-managed-business shape, SOI/Form 8960 level) with the anchor ingestion in PolicyEngine/chronicle#179. Until that lands this input stays at its zero default, so merging this PR changes no results — it makes the NIIT base able to receive the passive leg. |
The NIIT source list included rental income but omitted the section 1411(c)(1)(A)(ii) passive-business leg entirely. Add a passive_partnership_s_corp_income input (the section 469 passive subset of partnership_s_corp_income, which is already in gross income) and include it in gov.irs.investment.income.sources from 2013. Defaults to zero, so behavior is unchanged until data supplies it. The estate leg of #9304 stays out deliberately: estate_income is not in gross income today, so taxing it under NIIT first would be incoherent. Refs #9304 Co-Authored-By: Claude Fable 5 <noreply@anthropic.com>
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The NIIT source list (
gov.irs.investment.income.sources) included rental income but omitted the section 1411(c)(1)(A)(ii) passive-business leg entirely, so passive pass-through income was never taxed under NIIT.This adds a
passive_partnership_s_corp_incomeinput — the section 469 passive subset ofpartnership_s_corp_income, which is already in gross income, so including the subset in the NIIT base adds no income to AGI — and appends it to the source list from 2013 (NIIT has included passive business income since inception). It defaults to zero, so behavior is unchanged until a dataset supplies it; the Microcosm data side can populate it from the JCT/SOI passivity evidence gathered in Microcosm #530.Deliberately excluded: the estate-income leg of #9304.
estate_incomeis not ingov.irs.gross_income.sourcestoday (placeholder comments mark the spot), and taxing income under NIIT before it enters AGI would be incoherent — that leg is blocked on gross-income inclusion first, re-scoped on the issue.Tests: above-threshold NIIT computation with the new input (3.8% × min(NII, excess AGI)), below-threshold zero, and a default-zero regression case; also deduplicates two identically-named existing test cases.
Refs #9304
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