Taxing Beta, Exempting Alpha: A Benchmark-Based Inheritance Regime
This paper proposes a generational benchmark inheritance regime as a structural replacement for the federal estate tax. By distinguishing between systemic market returns (Beta) and active value creation (Alpha), the regime captures the passive growth of capital at generational boundaries while fully exempting idiosyncratic surplus. Using a Pareto tail interpolation (α ≈ 1.163) calibrated to Federal Reserve wealth data, we estimate baseline annual revenue of approximately $295 billion under conservative assumptions. This revenue is sufficient to finance a 2.1 percentage point reduction in the OASDI payroll tax, shifting the fiscal burden from labor to underperforming dynastic capital. Unlike continuous wealth taxes, the regime requires no new valuation machinery, relying exclusively on existing estate and gift tax procedures. We situate the proposal within the Jeffersonian principle of usufruct and the modern literature on optimal inheritance taxation.