This is an illegal law Congress passed and now it will just waste the Supreme Courts time. Unfair tax like this is specifically called out in our Constitution and Congress has no authority to pass a tax like this.
What will happen is one of these bonus receivers will simply refuse to pay it, and they will be in the right by not paying it. Then it will mushroom from there.
-S
PS. If this were allowed, you just opened the floodgates to tax any undesirable group that Congress wants to get rid of. This rings about as draconian as Hitler.
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