It would hit the top 0.01 percent of households, generating $360 billion over the next decade, with half of that coming from billionaires, according to the administration.

The administration said in a summary of the proposal that the tax code has rewarded wealth, not work, and contributed to growing income and wealthy inequality in America.

The minimum tax would make sure the wealthiest Americans pay a tax rate that is not lower than teachers and firefighters.

The plan comes as Democrats try to revive their long-stalled reconciliation plan and make good on their campaign promises to raise taxes on the rich.

It would open up a new revenue stream for the Treasury if people's unrealized gains in unsold assets were subject to taxes.

The wealth tax proposals by Elizabeth Warren and Ron Wyden have already been rejected by rank-and-file Democrats.

The proposal would be challenged as a violation of the Constitution's restriction on taxation.

The Washington Post reported that the plan would be released as part of Biden's budget request, which the administration says would reduce the budget deficit by a total of $1 trillion over the next 10 years.

The top 0.1 percent of earners will pay an average federal tax rate of 31.8 percent this year, according to the Treasury Department.

Some people at the very top of the income spectrum are able to cut or even eliminate their tax bills by borrowing against their stock holdings, which aren't taxed unless they are sold.

Over the past year, Democrats have repeatedly tried to address that, first with Warren's proposal to impose a yearly tax on the total value of assets held by the super-rich. The annual appreciation of those assets should be taxed.

Provisions in the code that allow wealthy people to pass assets on to heirs tax-free were previously proposed by Biden.

All of those failed to gain traction in Congress, with House Democrats pushing for more traditional income surtaxes on high earners.

The rich would have to pay the difference if the taxes on their income and their gains are less than 20 percent.

The White House document says that this approach means that the very wealthiest Americans pay taxes as they go, just like everyone else.

Those subject to the plan would be given years to pay their tax bills.

The proposal would allow wealthy households to spread initial top-up payments on income over nine years and then five years for top-up payments on new income going forward.

Taxpayers can pay later with interest.

Such a plan would likely be challenged as a violation of the Constitution's restriction on so-called direct taxes, an antiquated term referring to levies imposed directly on someone that can be shifted onto someone else.

Congress can tax people's earnings thanks to the 16th Amendment.

The Billionaire Minimum Income Tax is built into the administration's argument that unrealized gains should be considered income.

Wyden praised the plan.

He said that President Biden has put forward a proposal that would ensure billionaires pay taxes every year.

There is no way to fix our broken tax code without addressing the problem of billionaires avoiding taxes for decades.