Brian D. Galle (UC Berkeley), How to Tax the Ultrarich (Roosevelt Institute Jan. 2026) (fact sheet):

This report proposes a new tax, the Fair Share Tax (FAST), on very wealthy households. The FAST is imposed at sale like the current capital gains tax, but adds an interest-like extra tax on taxpayers who hold their assets for long periods. It therefore mimics the cash flows and economic incentives of a “mark-to-market” capital gains tax with a $15 million lifetime exclusion amount. Because it is collected at sale, the FAST is fully consistent with any possible constitutional limits that might rule out annual wealth or mark-to-market taxes. In addition, the FAST replaces the estate and gift tax system with an extra tax bracket for inherited property, in effect switching to an inheritance tax and carryover basis at death, but again with extra interest charges for taxpayers who delay sale.

The report also explores the economic, legal, and political rationale for the FAST and offers detailed descriptions of the legal rules needed to fit that rationale. Most importantly, it argues that US holders of vast wealth today enjoy opportunities to control social and political outcomes without spending their accumulated wealth. These facts make reforms to more effectively tax the ultrarich fairly urgent and imply that alternatives such as a value-added tax or other consumption tax would be ineffective at that goal.

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