First, it violates the origination clause of Article 1, Section 7 of the Constitution which clearly states that all revenue-raising bills must originate from the House of Representatives. This “tax”, as the Supreme Court ruled it, started in the United States Senate.
Second, this law violates the Takings Clause of the 5th Amendment of the Constitution which prohibits the Federal Government from compelling the direct transfer of money from one person or business to another.