Inheritance is a controversial institution. While a common narrative in Western societies holds that labor and merit are the legitimate titles for individual acquisition of wealth, common sense points out that some will receive inheritances, gifts, and bequestsFootnote 1 worth far more than what (most) others are able to appropriate in a lifetime of labor. Contemporary research on economic inequality supports this observation, showing that the distribution of wealth in Western societies is only loosely related to labor and merit (Atkinson Reference Atkinson2015; Piketty Reference Piketty2014). Instead, Thomas Piketty and others point out that inheritance plays an increasingly important role in private wealth accumulation – and is likely to continue to do so as long as intergenerational wealth transfers remain largely unrestricted (Piketty Reference Piketty2011; Piketty and Zucman Reference Piketty and Zucman2015)Footnote 2. This tendency has been reinforced by the fact that, over the past forty years, many OECD countries have either suppressed their inheritance and estate taxes (OECD 2021), raised the exemptions to extremely high levels (as in the United States: $13,99 million in 2025), or designed legal loopholes to shield those who plan their succession well in advance (the case of Belgium is paradigmatic). As a result, Western societies are moving away from the meritocratic ideals they claim to realize. It is rather the world described by Honoré de Balzac and Jane Austen in their novels, a world of inheritors struggling in a society structured by the promise of inheriting capital, which is unexpectedly knocking at their door.
But there is nothing ineluctable about this trend. One intuitive and obvious way to counterbalance it is to reinstate inheritance taxes. However, it does not seem appropriate to simply raise inheritance tax rates or restore tax regimes that were abolished not so long ago. Any attempt to reinstate inheritance taxation must do at least two things. First, it has to show that the new tax scheme is normatively superior to the old one because it is fairer. To do this, it must both satisfy the moral and philosophical reasons we have for taxing inheritance and offer answers to the moral objections to inheritance taxation. Second, to gain public support, it has to take into account the various reasons why so many countries have recently abolished their inheritance tax. Despite many exemptions, inheritance taxes are often perceived as a tax on the savings of a lifetime of work. They are based on an outdated concept of the nuclear family, which has been steadily losing ground in recent decades. Inheritance taxes, where they still exist, have also evolved into opaque and complex systems, crippled by exemptions that benefit the wealthiest households. In some countries, tax planning, targeted exemptions, and fiscal “optimization” have created a situation in which the middle class can legitimately have the feeling that the burden of taxation is not fairly distributed. Right-wing political parties have built on this feeling of unfairness to defend the abolition of the inheritance tax.
This response is misguided though. For a variety of reasons detailed in this article, we need an inheritance tax. But we need to adapt it to the two types of constraints just mentioned: the philosophical and moral expectations placed on inheritance taxation, on the one hand, and the social expectations regarding inheritance and distributive justice, on the other. This article claims that a lifelong accessions tax on capital received through inheritances, bequests, and gifts is a promising alternative way of taxing intergenerational wealth transfers that meets these two challenges. Due to length constraints, this article will not focus on the social expectations but rather on the philosophical challenge of imagining a fair tax on wealth transfers. The central claim is that, from a moral and philosophical perspective, a capital accessions tax (CAT) of the kind sketched in this article is normatively superior to the inheritance and estate taxes still in place in OECD countries. To make this case, this article proceeds in three steps. First, it surveys the political theory debate and provides a summary of the arguments for and against inheritance taxation. The second section provides a brief overview of how intergenerational wealth transfers are currently taxed in existing inheritance tax schemes (mostly in OECD countries) before outlining a plausible CAT. The third section then confronts these two options with the moral arguments and objections outlined in the first section and argues that the CAT is normatively superior to the average inheritance tax (AIT).
It is useful to clarify from the outset some of the things this article will not do. First, this article will not discuss what could be done with the revenue raised by the tax. Whether it should be used to invest in education, ecological transition, health care, or to fund a basic capital is a crucial discussion that we will have to leave asideFootnote 3. Second, any philosophical discussion of taxation should consider the tax system as a whole, not one of its parts in isolation. For the sake of brevity, however, we will have to focus on the CAT and assume, ex hypothesi, that it could “simply” replace existing inheritance tax systems. The claim is not that this single change would produce a comprehensive and just system of taxation, but that it would be an improvement in terms of distributive justice according to almost all sides of the philosophical debate. Third, doing this will require us to flesh out the structure of the CAT in more detail than has been done before in recent defenses of an accessions cap (M. Fleischer Reference Fleischer2016; Robeyns Reference Robeyns2024). This article builds on these defenses and complements them by responding to objections they did not address. Most importantly, it also provides a much more concrete description of how the CAT could work, of its thresholds and specifications, which are not discussed in other propositions. It also differs from these general accounts of the CAT by showing how the detailed proposition better answers not only arguments for (as Ingrid Robeyns’ recent article does), but most importantly also objections against inheritance taxation in the political theory literature. However, this paper cannot present a fully developed CAT scheme. Many qualifications remain to be discussed, if only to adapt them to the core values of the society that may decide to adopt them.
Inheritance taxation: a philosophical perspective
Is inheritance taxation morally justified? Overall, the political theory literature answers affirmatively. While the form and amount of the tax remain controversial, arguments strictly against inheritance taxation are the exception rather than the norm. The apparent consensus in favor of taxing wealth transfers may be an indirect consequence of another broad consensus on the harmful effects of large economic inequalities on social and political justice (Scanlon Reference Scanlon2018). The arguments for taxing inheritance have already been widely reviewed and worked out in the literature on the topic (Duff Reference Duff1993; Nagel Reference Nagel2009; Pedersen Reference Pedersen2018; Robeyns Reference Robeyns2024), but it is useful to recall them by stressing how they justify inheritance taxation by relying on one core value like equality of opportunity, merit, democratic equality, or utility. We will then review the objections to inheritance taxation.
(1) Fair equality of opportunity. The first and most important argument for taxing intergenerational wealth transfers is the promotion of fair equality of opportunity (FEO). At first sight, this argument is quite straightforward (even though the relation between inheritance and equality of opportunity is actually more complex; for a discussion, see: Bøyum and Pedersen, Reference Bøyum, Pedersen and Sardoč2023). The intuition is that two comparable individuals born in the same society with relatively equal skills and capacities should have access to similar life chances (Rawls Reference Rawls1999, 63). They may end up in different social positions after a few years, but this can be considered fair if the social structure did not arbitrarily favor or disadvantage one over the other. For Anne Alstott, this view implies “that every individual should begin life with a fair and equal share of society’s resources and that inherited wealth offers an unjustified advantage for some over others” (Alstott Reference Alstott2007, 470–71). Inheritances and bequests evidently threaten FEO since they randomly put some individuals in better positions than others. As David Haslett notes: “Wealth is opportunity, and inheritance distributes it very unevenly indeed” (Haslett Reference Haslett1986, 130).
(2) Merit. A second argument against inheritance is that it is arbitrary from a moral point of view. Being born to a large inheritance is a matter of brute luck, to put it in the terms of luck-egalitarians. Birth also has a disproportionate weight on the individual’s comparative ability to obtain a greater amount of highly desirable social goods through education or access to privileged social networks. Economic inequalities are unfair when they are the result of brute luck rather than the consequence of differences in merit, desert, or effort (Halliday Reference Halliday2018, 74–80). Inheritance taxation is one way to mitigate the morally arbitrary reward of brute luck. This argument has a corollary: it is fairer to tax inheritances and bequests than labor income since the former is morally arbitrary while the latter is directly related to differences in effort and merit. An additional reason for taxing inheritances and bequests therefore is that it could reduce the fiscal pressure on income by shifting the tax burden from “earned” income to “unearned” income.
Another interesting variation of this argument emphasizes how the snowballing accumulation of wealth over generations can threaten the proper functioning of the market society. According to Åsbjørn Melkevik, classical laissez-faire liberals like Milton Friedman, Friedrich Hayek, or Ludwig von Mises have at least two compelling reasons to defend inheritance taxation: it compensates for the fact that market societies do not reward merit, and it constitutes a powerful barrier against their natural tendency to transform into dynastic or oligarchic societies. As Melkevik writes: “The function of inheritance taxation is then to preserve open competition, a pillar of classical liberalism, which is essential if people are to accept market capitalism not as a system that arbitrarily rewards brute luck, but rather as a system of want-satisfaction, making them better-off” (Melkevik Reference Melkevik2019, 213–14). Inheritance taxation is necessary to create the appearance of a correlation between merit and wealth in the market society and to strengthen its acceptance.
(3) Democratic equality. Just as dynastic accumulation of wealth can distort market competition, the third argument points out that it can also threaten the kind of economic equality lying at the foundation of democratic societies. Many philosophers, from Aristotle to Jean-Jacques Rousseau, have pointed out that the proper functioning of a democracy requires some moderation in terms of economic inequality. More recently, this point has been revisited by John Rawls, who argued against the kind of economic inequalities permitted in welfare state capitalism on the grounds that such inequalities convert into political inequalities that threaten the liberties protected by the first principle of justice (O’Neill Reference O’Neill2009, 382–85; Rawls Reference Rawls2001). As Rawls puts it, an important reason to control economic and social inequalities is “to prevent one part of society from dominating the rest” since “this power allows a few, in virtue of their control over the machinery of state, to enact a system of law and property that ensures their dominant position in the economy as a whole” (Rawls Reference Rawls2001, 130–31).
Additionally, the unchecked transfer of substantial wealth across generations fosters enduring social stratification and hinders social mobility (Halliday Reference Halliday2018, 101–21; Pedersen Reference Pedersen2018, 10). This is detrimental to the democratic ideal since, in the words of Thomas Nagel: “Class stratification involves the creation and maintenance of layers of society that persist through time, with a presumption that one will stay in the layer into which one is born” (Nagel Reference Nagel2009, 117). Overall, dynastic wealth transfers are particularly problematic because they tend to create small elite groups of individuals who inherit significant wealth and power from their ancestors, can gain preferential access to highly desired social and economic positions, and pass this status on to their children through generations (M. Fleischer Reference Fleischer2016). Such an aristocratic elite reproduces itself and can, in some circumstances, dominate both the economic and the political life of a democratic society for a long time.
(4) Utility. Finally, there is a welfarist or utilitarian argument for taxing inheritance (Robeyns Reference Robeyns2024, 6–7). The idea here is that, since the individual marginal utility of owning wealth declines after a certain point, a social system in which wealth is more equally distributed will generate more utility. Summarizing the argument, Nagel writes:
Economic inequality leads to spectacularly unequal levels of consumption per person, and this is wasteful because of the unequal marginal utility of expenditures by rich and poor. The utilitarian aim of equalizing marginal utility makes it desirable to redistribute resources downward if this is practicable, and inheritance taxes are one obvious means of doing so. (Nagel Reference Nagel2009, 114–15)
An interesting variation of this argument was proposed by Haslett (Reference Haslett1986: 134), who points out how the “enormous concentrations of economic power” generated by unrestricted transfers distort the supply-demand mechanism lying at the heart of the market economy. Since the supply curve is shaped by the effort of the producer to catch the “dollar votes” held by the consumers, and since these “votes” are concentrated in the hands of a wealthy minority, the existing wealth concentration gives the 1% a disproportionate influence on the supply curve. As a result, general production will inadequately reflect actual preferences in society and decrease general utility since the goods produced do not reflect the actual preferences of the majority. A tax on inheritance can contribute to tempering this bias while increasing general utility through distributing wealth more equally.
We can now turn to the arguments against inheritance taxation. As noted above, they are not dominant in the contemporary political theory literature. A few authors have either alerted to the unexpected and undesirable effects of inheritance taxation (Bracewell-Milnes Reference Bracewell-Milnes, Erreygers and Vandevelde1997), narrowly criticized existing inheritance tax regimes from an (allegedly) liberal perspective (McCaffery Reference McCaffery1994), or denounced the economic rather than political consequences of inheritance taxation (Block Reference Block2012; Tullock Reference Tullock1971). These dissident voices did little to dent the overall academic consensus about the need for inheritance taxation. Despite having little academic support, objections to inheritance taxation have however widely disseminated outside academia and remain well alive in contemporary public debates. Hence, it is crucial to recall them and examine whether and how an alternative tax proposal can respond to the common fears they express. These arguments usually take one of the following forms: inheritance taxation is wrong because it threatens the value of the family, because it undermines individual incentives and hurts economic productivity, or because it violates the right to private property (Melkevik Reference Melkevik2022, 2). For the sake of brevity, we will leave aside other objections that have already been convincingly refuted (such as the double taxation, equity and virtue objections. See Fleischer, Reference Fleischer2022; O’Neill, Reference O’Neill2007; White, Reference White2018, Reference White2025: 120–132) and will focus on these three objections since they are the most likely to motivate public opposition to inheritance taxation.
(a) The family objection. This objection builds on the idea that the family is a core value of Western societies and that abolishing inheritance threatens it. It echoes the fact that, in countries where inheritance and bequests are still taxed, a family exemption is usually in place to allow the transmission of the family home, farm, or business. Despite criticisms pointing out that the institution of inheritance also constitutes an important threat to family values and parental love (Bastin Reference Bastin2023; Neves Reference Neves2023), this objection remains powerful today. According to Jørgen Pedersen (Reference Pedersen2018: 3–4), the objection has three variantsFootnote 4. The first one is grounded in the idea that parents have a right to be partial and favor their children through inheritance, gifts, and bequests. While acknowledging that the parental right to be partial allows for some kind of transfers because they promote valuable relationship goods, Harry Brighouse and Adam Swift stress that it cannot justify an unconditional right to transfer wealth (Brighouse and Swift Reference Brighouse and Swift2009). The common objection to inheritance tax further emphasizes that leaving an inheritance should be considered virtuous and be encouraged rather than condemned (Pedersen and Bøyum Reference Pedersen and Bøyum2020, 303–4). Second, it can be argued that it is not the individual who owns his wealth but rather the family to which the individual belongs. When a child inherits, he simply replaces his parents as the owner of the wealth belonging to the family. From this perspective, taxing intergenerational wealth transfers is illegitimate because, somehow, there is no transfer in the first place (Pedersen and Bøyum Reference Pedersen and Bøyum2020, 305–6). Third, Robert Nozick provides an identity-based argument to justify the creator’s right to pass on to her descendants a thing in which part of her identity is embodied, as a means of renewing and strengthening their bonds. (Nozick Reference Nozick1989, 291–93)Footnote 5. This last version of the argument points to another reason for protecting the transfer of property within the family. Some things have a special, non-financial, sentimental value to members of a particular family that justifies their right to receive them as an inheritance. The family home, the family business, the family farm, ancestral artwork, and potentially every type of personal property that expresses its former or original owner’s personality (and is accordingly emotionally invested by its future inheritor) fall into this category (as opposed to financial titles or cash, which are somewhat impersonal). Finally, Catarina Neves also highlighted the importance of reciprocity in the common will to pass to one’s own children the kind of head start one did receive earlier from his parents (Neves Reference Neves2023, 30–31). However, she concludes similarly to Brighouse and Swift that the value of reciprocity cannot justify an absolute right to transfer property to one’s children.
(b) The productivity objection. The second objection to taxing wealth transfers is that it would reduce existing incentives for individuals to work, save, and invest. If individuals knew that the government would take their wealth when they die, they would have less incentive to work hard and might prefer to consume their wealth rather than invest or save it for their descendants. Moreover, the objection goes, increased taxation of inheritances and bequests will encourage high-income workers and wealthy individuals to respond by moving to states or countries where tax rates are lower. This fiscal exile will deprive the economy of both its skills and tax revenues. Overall, any increase in inheritance taxation would, the objection goes, result in a net loss of economic efficiency and tax revenue.
(c) The property objection: The third kind of argument against inheritance taxation claims that it violates the right to private property. According to its proponents, the right to private property includes the unqualified right to give and bequeath. If the right of private property includes the power to use and destroy property at the owner’s will, then it must also necessarily include the lesser powers to sell, bequeath, or simply give it away. As Murray Rothbard points out:
For if individuals have the right to their labor and property and to exchange the titles to this property for the similar property of others, they also have the right to give their property to whomever they wish. And of course most such gifts consist of the gifts of the property owners to their children – in short, inheritanceFootnote 6. (Rothbard Reference Rothbard2006, 49–50)
This type of argument is usually associated with libertarianism, although it should be noted that libertarians are divided on the issue of inheritance taxation (Demuijnck Reference Demuijnck2006; Fried Reference Fried2004). Left-libertarians generally side with liberal egalitarians in defending the need for government redistribution through inheritance taxation (Steiner and Vallentyne Reference Steiner and Vallentyne2000), but the case is more controversial among right-libertarians. The classical position holds that no argument – not even a straw man argument – can justify inheritance taxation within the Lockean-libertarian framework (Twele Reference Twele2023), but other libertarians have more nuanced positions. Nozick, for instance, argued in The Examined Life that the worker should have the right to bequeath to her children what she earned through her own labor, but not what she herself received as a gift, bequest, or inheritance (Nozick Reference Nozick1989). Daniel Halliday also noted that right-libertarians have good reasons to fear the unrestricted operation of the “free transfer principle” since it might create a dynastic society where, contrary to their individualistic and meritocratic values, wealth and social status depend on arbitrary factors such as birth (Halliday Reference Halliday2018, 160–61). Miranda Fleischer further stressed that right-libertarians also have strong internal reasons to support the taxation of gratuitous wealth transfers as it could replace even less legitimate sources of government income like income or consumption taxes (M. P. Fleischer Reference Fleischer2022). Despite some doubts in the academic debate, the property objection however remains the strongest one against inheritance taxation in the public debate, and we must consider it accordingly.
How to tax inheritance?
The arguments and objections detailed in the previous section allow us to identify the different functions and challenges that a fair inheritance tax system must perform and confront. These arguments and objections are useful to evaluate the respective merits of the different alternatives in terms of inheritance taxation. An inheritance tax system that achieves more equality of opportunity (1), gives more weight to merit – or option luck – than to brute luck (2), preserves democratic equality (3) and creates more utility will better fulfill the moral expectations we place on any inheritance tax system and will prove normatively superior to any alternative that does not perform as well on these indicators. Moreover, if it can answer or mitigate the main objections to inheritance taxation by allowing room for family values (a), preserving economic incentives (b), and respecting property rights (c), an inheritance taxation scheme can also greatly undermine the arguments against its implementation. With these criteria in mind, the next step is to outline the main characteristics of the AIT in the OECD and of the lifetime CAT before assessing in the next section whether they meet the requirements of a fair inheritance tax.
Inheritance taxation in OECD countries
The first thing to note when examining inheritance taxation in OECD countries is that the general trend has been to remove inheritance taxes rather than to increase them (OECD 2021). Among the countries maintaining an inheritance tax, we can distinguish between two main approaches. Some countries impose a donor-based tax on the deceased’s estate (Denmark, the United Kingdom, and the United States), while civil law countries tend to impose a recipient-based inheritance tax: the tax is calculated on the value of the assets received by each heir. Inheritance taxes are also often characterized by double progressivity: the tax rate increases both with the value of the assets received and with the genealogical distance between the donor and the recipient, while estate taxes tend to favor a flat rate beyond a certain exemption (Jestl Reference Jestl2021).
Among the countries still taxing inheritance, there is an incredible variety of rates, exemptions, and special regimes. It is certainly beyond the scope of this article to review the many peculiarities of each national system, but we can highlight five of their common features in order to give an overview of the AIT (Drometer et al. Reference Drometer, Frank, Pérez, Rhode, Schworm and Stitteneder2018; Jestl Reference Jestl2021; OECD 2021). First (I), an inheritance tax has specific partial or total exemptions to protect the spouse/partner of the deceased (Jestl Reference Jestl2021, 369). Similarly, direct descendants and members of the nuclear family always benefit from higher exemptions and/or lower tax rates (Drometer et al. Reference Drometer, Frank, Pérez, Rhode, Schworm and Stitteneder2018). These exemptions show a clear preference for intrafamilial transfers over extrafamilial transfers. Second (II), inheritance tax schemes allow specific assets to receive preferential treatment either because their origin justifies their remaining in a definite family (such as family homes, businesses, and farmland) or because their preferential treatment creates economic incentives to invest in them (such as business or pension assets and life insurance policies) (OECD 2021, 100–109). Third (III), with the notable exception of Ireland, all tax systems operate on a discrete rather than a continuous basis: the tax is levied on each estate or inheritance, regardless of what the individual has previously received from anterior gifts or bequests. Large gifts received up to ten years before the donor’s death are usually included in the valuation of the estate, but the recall period is usually short enough to allow for long-term tax optimization by giving valuable assets well in advance.
This brings us to a fourth (IV) rather informal feature of OECD inheritance tax systems: they provide ample room for tax planning, fiscal engineering, and concretely, tax optimization for the wealthiest (OECD 2021, 122–28). On the one hand, almost all countries taxing inheritance and bequests also tax inter vivos gifts. Yet on the other hand, relatively high annual exemptions, favorable treatment of real estate, and relatively short recall periods (3 years in Belgium, 7 years in England) allow donors to minimize the cost of transferring assets by planning their succession well in advance. There are also various specific national options to pass on wealth with preferential tax rates (or no tax at all), such as the use of trusts in the United States or the United Kingdom. Lastly (V), the AIT generates little fiscal revenue despite a very large basis and seemingly high rates. Where it still exists, inheritance tax accounts for an average of 0.51% of tax revenue and exceeds 1% in only four OECD countries (OECD 2021, 75). This limited contribution can be explained by the various legal loopholes lowering the effective taxation rate of (large) intergenerational wealth transfers. As a result, effective tax rates are significantly lower than statutory tax rates (OECD 2021, 98) and, in some cases, even decline for the wealthiest taxpayersFootnote 7. All in all, inheritance taxes are far from being confiscatory, especially when preventive measures such as donations and tax optimization are used.
The lifelong capital accessions tax in theory…
A lifelong CAT is a progressive and cumulative tax levied on the capital received by an individual without labor, merit, or effort throughout his or her lifetime. The origins of this proposal date back to a time when inheritance played an even more important role in individual wealth accumulation than it does today. In the mid-nineteenth century, John Stuart Mill criticized the glaring disparity he witnessed between the leisurely lifestyles of extremely wealthy heirs and the arduous toil of the working class. This disparity struck him as particularly unjust, since he believed that private property was justified by individual labor and merit in a very Lockean way (Mill Reference Mill and Robson1965a, 208). He deeply regretted that the actual distribution of property was apportioned
almost in an inverse ratio to the labour – the largest portions to those who have never worked at all (…), the remuneration dwindling as the work grows harder and more disagreeable, until the most fatiguing and exhausting bodily labour cannot count with certainty on being able to earn even the necessaries of life. (Mill Reference Mill and Robson1965a, 207)
To preserve the legitimate connection he saw between labor and appropriation, Mill defended the abolition of inheritance taxation and its replacement by the limitation of the amounts one can receive through gifts and bequests. His proposal provides an adequate starting point for thinking about a renewed accessions tax since, on the one hand, it is the common reference of most advocates of the accessions tax today, and on the other hand, it directly aims at answering the property objection (c) to inheritance taxation. What Mill does in his Principles of Political Economy is precisely to go back to the roots of the concept of private property (in chapters 1 and 2 of book II) to show that if labor rightly justifies private appropriation, then appropriation without labor must be limited in order to prevent the free operation of the principle from undermining the very reasons that justified the existence of private property in the first place. To do this, Mill suggests the following:
Were I framing a code of laws according to what seems to me best in itself, without regard to existing opinions and sentiments, I should prefer to restrict, not what any one might bequeath, but what any one should be permitted to acquire, by bequest or inheritance. Each person should have power to dispose by will of his or her whole property; but not to lavish it in enriching some one individual, beyond a certain maximum, which should be fixed sufficiently high to afford the means of comfortable independence. The inequalities of property which arise from unequal industry, frugality, perseverance, talents, and to a certain extent even opportunities, are inseparable from the principle of private property, and if we accept the principle, we must bear with these consequences of it: but I see nothing objectionable in fixing a limit to what any one may acquire by the mere favour of others, without any exercise of his faculties, and in requiring that if he desires any further accession of fortune, he shall work for it. (Mill Reference Mill and Robson1965a, 224–25 bk. II, ch. 2, §4)
Two features of Mill’s proposal interestingly differ from the AIT. First, it reverses the focus of the tax. Rather than taxing the amount given every time someone dies (or makes a taxable gift), Mill claims we should record all the significant gifts and bequests received by an individual throughout her life. This allows for more horizontal equity since, in Mill’s system, two individuals receiving the same amount of capital throughout their life will pay the same tax, whereas in contemporary systems, the tax rate depends on variables such as the family relationship between the giver and the receiver, on various exemptions, and is independent of what the individual has received before in inheritances, gifts, and bequests from other sources. Second, because appropriation without labor is so loosely related to merit and effort, and because it plays such an important role in the reproduction of wealth inequalities, in the Principles of Political Economy, Mill defends a ceiling to the amount an individual can receive from others throughout his lifeFootnote 8. Beyond this fixed amount, one cannot receive anything anymore and has to work if she wants to further increase her wealth.
Mill’s proposal had an ambivalent legacy in political theory. On the one hand, it had an important influence on major thinkers in sociology, political theory, and political economy. Émile Durkheim, James Meade, James Buchanan, John Rawls, and Anthony Atkinson, for instance, all declared themselves in favor of implementing Mill’s scheme (Atkinson Reference Atkinson2015; Buchanan Reference Buchanan1985, 133–34; Durkheim Reference Durkheim2015, 317–35; Meade Reference Meade1964; Rawls Reference Rawls2001). The lifetime accessions tax also sporadically reappeared in political theory debates in the twentieth century (Andrews Reference Andrews1966; Haslett Reference Haslett1986; S. Carroll Reference Carroll1989; Duff Reference Duff1993), but it is only with the unprecedented rise of economic inequalities and the debates they generated at the beginning of the twenty-first century that it gained a strong renewed interest. A significant number of authors defended a lifetime accessions tax, arguing that it could contribute to a more equal distribution of property and support the core liberal-egalitarian values (Dodge Reference Dodge2009; Bird-Pollan Reference Bird-Pollan2016; M. Fleischer Reference Fleischer2016; Frémeaux Reference Frémeaux2018; Batchelder Reference Batchelder2020; Robeyns Reference Robeyns2024). On the other hand, this wide academic endorsement produced little to no concrete political effects. The lifetime accessions tax never gained any strong political support in Western countries and, to my knowledge, does not figure on the menu of plausible tax reforms in major political parties.
How to explain the public invisibility of the CAT? The answer has at least two sides. First, philosophical defenses of the accessions tax usually focus on its desirability, i.e., on the moral and philosophical arguments in favor of the CAT. By doing so, they neglect the objections to inheritance taxationFootnote 9. Yet these objections seem to be important in the Western social imaginary and can partly explain why it is so difficult for the accessions tax to gain public support. Second, and most importantly, the literature on the accessions tax failed to make it look concrete. The articles on the topic usually discuss the tax on a very abstract level. While philosophers are comfortable to defend the accessions tax from the standpoint of political theory, they are usually reluctant to provide numbers about how much one should be allowed to receive throughout his life and what kind of measures would accompany this radical change in succession law. For a representative example, Ingrid Robeyns’ recent article makes a very persuasive argument in favor of the tax, but only marginally addresses the objections and very reluctantly concedes to give a number of the ceiling proposed: $100,000 (Robeyns Reference Robeyns2024, 18). Moreover, when philosophers do give their take on the maximum amount one should be able to receive, they usually remain silent on eventual accompanying measures. An interesting parallel could be made with the Universal Basic Income debate. As long as the proposal remains theoretical and does not include an amount to discuss or does not state whether the monthly payment is added to or replaces social security, it is impossible to debate it concretely, and it remains inaudible politically. The same applies to the CAT: in the present state of the debate, it is difficult both not to agree with philosophers on the necessity of an accessions tax and to picture what it would concretely look like.
…And in practice
To remedy this, we have to fill in the blanks of Mill’s proposition and sketch an updated version of the CAT. The first thing to clarify is whether we will have one or two thresholds. The first option implies that the tax rate on received wealth is either 0 or 100%. This is, for instance, the option defended by Robeyns in her recent article. Every individual can receive wealth up to a certain threshold (about $100,000), but nothing more. Hence, this proposal is usually called a lifetime accessions cap rather than tax. The second option – the one defended here because it better replies to objections to inheritance taxation as we will see in the next section – is to consider two thresholds. The first one sets the level of the general exemption below which no one pays the tax. The second sets the maximum amount an individual can receive “without any merit or exertion of [his] own” (Mill Reference Mill and Robson1965a, 208). Between these two thresholds, a progressive tax is levied on the wealth received that becomes confiscatory when closing on the second threshold. The proposal is therefore best called an “accessions tax with a cap” (but we will continue to refer to it as the “accessions tax” and reserve the “accessions cap” to proposals with a single threshold). These thresholds, of course, must not be fixed once and for all but should vary in a predictable way according to one or more economic indicators. This indexation will allow automatic adjustment of the thresholds to macroeconomic trends and inflation. In addition, in order to reduce the influence of exceptional events on these thresholds (such as COVID-19 or the war in Ukraine), they should be indexed on the value of an indicator measured over the past five or ten years.
My suggestion is to set the lower threshold at a value corresponding to the mean amount annually received per individual in gifts, inheritances, and bequests (over the previous five years). Since the mean is usually significantly higher than the median in wealth transfer distributions, this threshold implies that more than half the population will not pay any tax when they receive wealth from a parent or a friend. Determining the upper threshold is more difficult. Mill’s suggestion is that it should be “fixed sufficiently high to afford the means of comfortable independence.” We can interpret this to mean that an individual should be able to live as a rentier on his inherited capital. In economic terms, this can mean an amount of such value that it produces annually the equivalent of the mean wage in capital income. To set the limit, we can simply look at the average wage and the average rate of return on capital over the past five years, and determine the value of that capital that produces annually an average wage (after taxes) in capital income. Between these two thresholds, a progressive tax rate determines how much tax is due when a transfer occurs. As mentioned earlier, the tax rate will depend on the total of gifts and bequests previously received by the beneficiary during his whole life. For simplicity, we assume that the progressivity of the tax rate is linear and begins to apply only to the amount received above the lower threshold. The tax rate would then progress from 0 to 100% from the lower to the upper threshold.
What would this proposal look like in concrete terms? In the absence of reliable data on inheritances and bequests in the United States, we can turn to the 2019 Survey of Consumer Finances. According to that survey, the bottom 50% received an average of $9,700, the next 40% received $45,900, the next 9% received an average of $174,200, and the final top 1% received an average of $719,000. (Bricker et al. Reference Bricker, Goodman and Moore2020). To encourage public support, the lower threshold could be set at the average received by the 50 to 90% of the distribution, i.e., $45,900. Regarding the upper threshold, given a national average annual wage of $65,470 in April 2024, we can infer that inheriting a capital that generates $66,000 in interest per year will provide the means for “comfortable independence.” Assuming an interest rate of 4%, this corresponds to $1,650,000. In France (2018), with similar thresholds, nobody will pay the inheritance tax before having received 135,000 EUR (INSEE 2021), while no one can receive more than 925.000 EUR in gifts and bequests (37,000 EUR per year in interest at 4%). In both cases, more than half of the population will not be bothered by the tax at all, while only an extremely small minority will even have to think about the upper threshold.
To these two thresholds, we need to add six measures or “qualifications” to clarify the transformations implied by the CAT sketched here. Let’s start with three general and uncontroversial qualifications that we find in existing tax schemes (Gross, Lorek, and Richter Reference Gross, Lorek and Richter2017). First, there should be a total exemption for the surviving spouse or partner. Special provisions should also be made to enable parents unexpectedly struck by death or illness to guarantee their children a similar quality of life until they reach adulthood or to provide resources for the elderly or disabled relatives they have supported during their lifetime. Second, since inter vivos gifts of all kinds (cash, life insurance, financial products, trusts, land, housing, etc.) are included in the quota, we need to add an annual limit to small gifts that are not counted. The goal of this measure is to avoid having to report every birthday gift. This limit can be set relatively high (say $1000 per year) without compromising the spirit of the CAT. Third, all gifts and transfers of wealth to nonprofit and public organizations of general interest should be exempt from taxation. However, specific laws must ensure that these nonprofit organizations are not used by donors to further their own interests directly or indirectly, either by retaining control of the nonprofits’ assets or by using them as a proxy to keep the transferred wealth under their (or their family’s) control. While a positive side effect of the CAT is that it encourages the dispersal of wealth and donations to nonprofits and charities, great care must be taken to avoid the potential result that these privately funded (and therefore undemocratically controlled) organizations end up replacing the state’s action in health, education, social security, research, and so on. The democratic control of nonprofit organizations is a separate problem that we cannot address here but which I believe can be addressed in a satisfactory way within the CAT.
Now let’s look at what happens when someone dies. The state would first carry out the transfers of wealth stipulated in the individual’s will, i.e., verify and apply individual exemptions, collect taxes on nonexempt transfers, eventually block transfers to those who have already received more than the maximum allowed, and temporarily seize what’s left or not properly bequeathed. In order to avoid that the state ends up owning de facto a significant part of the housing market and/or of large companies after a few decades, a fourth qualification is needed. The state must auction off all real estate, stock market shares, land, etc., that it acquires as “residual inheritance” within a certain number of yearsFootnote 10. Specific preemption clauses should, of course, ensure that goods of public interest can be repurchased by the public, but the general rule would be that private property that has not been properly bequeathed will be sold by the state through public auctions on a dedicated market. There may be strong moral reasons to exclude for-profit companies from accessing this sale, but this is not the place to discuss them.
Since the owner’s right to give is, in some cases, limited by the recipient’s inability to receive, we can add a fifth qualification: the owner has the right to give a preemption right to the beneficiary of his choice. The designated receiver would not receive the thing as such but rather have a right to buy the thing at its market value before the state auctions it. This measure is a compromise to allow the continuation of family businesses, the transfer of expensive family homes and farms, or other valuable assets, on the condition that the designated beneficiary can pay for the value of the portion exceeding the upper threshold allowed by the quota with his own funds.
A sixth and last measure is therefore needed: any citizen lacking the means to buy a thing on which she has received a preemption right should have access to state-provided credit under reasonable conditions. Given that the people who will need access to these credits are likely to have already received the maximum amount allowed by the scheme, it seems fair to allow them to buy those goods on which they have a preemption right, but only on the condition that they pay their fair market price. Interestingly, this sixth qualification creates a proportion between the size of the exceeding part an individual can buy as pre-empted inheritance, bequest, or gift and the value of their labor earnings and income perspectives. We could imagine many other qualifications, but for now, it seems to be sufficiently fleshed out to be compared to the AIT.
Average inheritance tax vs. capital accessions tax
Let’s now build on the philosophical arguments and objections seen in the first section to assess and compare the AIT and the CAT. Starting with the CAT, it unsurprisingly finds strong support from arguments in favor of inheritance taxation. The CAT outlined in the previous section would significantly promote (but not fully realize) FEO by precluding the transmission of extremely large fortunes while allowing parents to provide a consistent (but not disproportionate) head start to their children or loved onesFootnote 11 (1). The upper limit set to the amount one can receive without working would ensure that, despite some inequalities remaining because of family preferences, a connection between labor, merit, and appropriation exists (2). Successful individuals who have managed to accumulate wealth over the course of their lives will retain the right to dispose of it, provided that they do not enrich one or more others in a way that threatens democratic equality or consolidates existing social stratification (3). Finally, the CAT creates important incentives to disperse wealth as there is only so much you can give to your children. The dispersion of wealth will increase general utility and more evenly distribute the “dollar votes” among consumers (4).
How does the AIT compare? As we have seen in the previous section, despite evident diversity, the AIT is characterized by five features: large exemptions for family members (I); significant exemptions for family homes, farms, businesses, and specific financial assets (II); tolerance for anticipated donations (III) and fiscal engineering to avoid paying inheritance tax (IV); and, as a result, low effective tax rates and redistributive effect (V). Given these five features, the AIT does significantly worse than the CAT regarding why we should tax inheritance. Because of its low redistributive effect, the AIT does not do much to achieve FEO (1) or promote individual merit (2). It rather accentuates the concentration of capital and consolidates dynastic wealth. The large unchecked transfers taking place under the AIT undermine social mobility and threaten democratic equality (3). The inequalities they perpetuate and amplify also conflict with utilitarian ideals, giving more weight to the preferences of the wealthiest in the economy (4). The CAT therefore undoubtedly goes far beyond the AIT in fulfilling the four main reasons we have for taxing the intergenerational transfer of wealth.
What about the objections to inheritance taxation? Since the AIT in fact does not levy a significant tax on wealth transfers, it seems better able to avoid these objections than the CAT. However, this does not necessarily make a case for the AIT over the CAT in a decisive way. To do that, three additional points need to be made. First, the three objections outlined in the first section must be valid and constitute sufficiently strong moral or economic reasons to limit or prohibit inheritance taxation. Second, it should also be clear that the AIT addresses the relevant aspects of the objections better than the CAT. If the CAT can offer similar or equivalent guarantees to the relevant parts of these objections, then it remains normatively superior to the AIT because it better satisfies the other motivations we have for taxing inheritance. Third, the benefits of the AIT better responding to a crucial objection to inheritance taxation should also be weighed against the benefits of satisfying the moral reasons we have for supporting inheritance taxation, as realized by the CAT. We therefore need to adopt a comparative perspective when assessing whether the AIT and the CAT expose themselves to the general objections to inheritance taxation.
(a) Let’s start with the family objection and AIT. It first has to be noted that the protection given to transfers within the family is not absolute but depends on the level of the exemption in place in each country. The existence of an exemption therefore does not clear out the objection once and for all, but it decreases its weight in an inverse proportion to the level of the exemption. Moreover, it is not completely clear that protecting inheritance from taxation really strengthens family ties and that inheritance taxation should be objected to on this ground. When used to blackmail a child or exercise discretionary power over future heirs, the power to bequeath harms the value of the family rather than supports it. If, in a given society, the power to bequeath reproduces gender inequalities (Gollac and Bessière Reference Gollac and Bessière2020) or gives an undue power to parents over their children (Bastin Reference Bastin2023), then the family objection is even more deforced. Note also that not all intrafamilial wealth transfers serve the value of the family in the same way. It is one thing to bequeath the family home and a bit of cash, it is another to give large sums of cash, investments in real estate and financial assets that are related to the family only in name. While the family objection works well for the first category, the same cannot be said for the second. For this reason, Bøyum and Pedersen conclude that none of the five versions of the family objection succeeds in condemning inheritance taxation where a proviso exists to protect modest transfers within the family (Pedersen and Bøyum Reference Pedersen and Bøyum2020).
For the same reason, the family objection is not strong enough to condemn a CAT of the kind described in the previous section. With the qualifications mentioned in the previous section, the right of the spouse/partner is fully protected, and the proposed thresholds allow the vast majority of the population to pass on their wealth to their children or loved ones with little or no tax. In cases where the children receive an amount between the lower and the upper threshold of the CAT, they have to pay a tax that may be significant on what they receive, but they are still in a better position than under an AIT since they will be able to access state-provided credit if needed. It will be their choice whether they value these properties so much that they want to pay the tax or borrow the money to pay it. It is only the minority inheriting more than the CAT upper threshold that ends up in a less favorable position in comparison to the AIT (especially if one assumes that fiscal optimization allowed them to pass their wealth almost unchecked under the AIT).
Yet two observations temper the significance of their loss. First, for the situation of this minority to matter from the family values’ point of view, it must be shown that the part they will not receive in a CAT actually concerns objects or properties that matter for the family. This is especially dubious as large inheritances are usually constituted by intangible and unpersonal assets like cash or financial titles rather than by affectively invested objects or artifactsFootnote 12. Second, supposing that the testator will have given his children a preemption right because the remaining assets really matter for the family, most receivers will already have been largely endowed and will be able to selectively rebuy some of the assets they find most important. If necessary, they can even borrow money on favorable terms to do that. Overall, the excess part of inheritances that a small minority will be deprived of under the CAT only marginally matters for family values. The CAT therefore seems to be a major improvement, especially if we consider that the bulk of the middle class that now sometimes has to pay taxes to inherit the family house will likely not have to under a CAT with a moderately high upper threshold.
It might be objected that the skyrocketing prices of the housing market in large cities can create situations in which it will remain impossible for a young adult to receive (or buy, using his preemption right) a family home or apartment that was purchased decades ago for a fraction of its current market value. To remedy such situations, the CAT is interestingly modulable. We can imagine, for instance, the creation of an additional family house exemption that simply states that everyone has the right to receive from a close family member one (and only one) property whose value is not included in the quota, on the condition that they live in it. Renting it or taking financial advantage of the estate would be forbidden since it would go against the intention of the quota and would conflict with FEO and democratic equality. If and when the heir decides to sell the family house, she will simply be taxed at that moment as if she had received the money from the sale as an inheritance. A similar exemption could be made for family valuables, gifts, or works of art that are not intended to be sold. For example, the daughter of Jeff Koons could be denied the opportunity to receive gifts from her father because of their value, despite being willing to enjoy the sculptures privately. In such cases, it is the (possible) sale of these assets, not their private enjoyment, which creates economic inequality. An additional exemption could therefore be made to allow individuals to keep these gifts on the condition that they do not rent them, sell them, or convert their sentimental or symbolic value into financial value.
(b) Let’s now turn to the productivity objection. The impact of inheritance taxation on economic incentives is incredibly difficult to measure because of the many factors involved, but a tentative consensus tends to emerge in the economic literature to consider it as relatively limited (OECD 2021, 52–62). This is intuitively confirmed by the fact that countries taxing inheritance, gifts, and bequests do not seem to be less productive overall than those that do not do so. In OECD countries, at least, the existence of an inheritance tax does not seem to be significantly correlated with economic productivity. The reasons why people accumulate wealth are manifold, complex, and often unclear – even to themselves (Fried Reference Fried1999, 646–53). Restricting the ability to freely give, bequeath, or receive wealth only has a limited effect on an individual’s labor supply because it does not affect other motivations such as social prestige, moral satisfaction, or simply social habits. This also explains why childless economic agents are not less productive than their counterparts who have children (Frémeaux Reference Frémeaux2018, 71; Fried Reference Fried1999, 648–49).
Moreover, data on fiscal mobility collected in the United States and Switzerland suggest that inheritance taxation has little to no effect on mobility behavior, even when individuals can easily respond to a higher tax rate by moving to another state or canton in the same country rather than moving abroad (Brülhart and Parchet Reference Brülhart and Parchet2014; Conway and Rork Reference Conway and Rork2006, Reference Conway and Rork2012). Paul Caron and James Repetti (2013) even suggest that taxing inheritances will have an overall positive effect on economic growth because it reduces the concentration of wealth and decreases the burden of taxation on income. There is however no definite consensus on the question. Slemrod and Kopczuk (Reference Slemrod, Kopczuk, Gale, Hines and Slemrod2000), for instance, predict that “an estate tax rate of 50% would reduce the reported net worth of the richest half percent of the population by 10.5 percent when its effect is fully realized many years later” (p. 32–33). This prediction however does not identify whether this would be due to tax evasion or to reduced incentives (Pedersen and Bøyum Reference Pedersen and Bøyum2020, 309) and cannot apply to a CAT that would cut the incentives to bequeath only to a small fraction of the population.
In the absence of reliable economic conclusions, we can stress that, in comparison to the AIT, the CAT rather offers better answers to the concern of diminishing incentives for wealthy inheritors. Consider first the “Carnegie effect,” named after Andrew Carnegie, who famously claimed that children of successful entrepreneurs spoil their talent and their energy when they’re promised a large inheritance. The CAT will avoid such waste by creating new incentives for otherwise born rentiers. Second, the CAT will apply only to a minority of workers at the top of the income distribution. For these high-income workers, however, the ability to accumulate and bequeath wealth is only one of the many reasons explaining their labor supply. Other motives, such as social recognition, the exercise of power in the workplace, or simply “wealth accumulation as an end in itself” (C. Carroll Reference Carroll2000), contribute to explain why high-income individuals work hard. These other motives will not be affected by the CAT. Third, any hypothetical negative effect of the CAT on incentives should be offset by the new incentives created by a wider distribution of wealth, especially as the CAT will decrease social stratification and give new perspectives of success to the most competent of those who previously had little or no chance of earning top incomes or reaching top positions because they were not born to it. If they succeed, they will be more competent than those they replace, which should also increase overall productivity (Haslett Reference Haslett1986, 145). Fourth, Luc Arrondel and André Masson point out that early transfers of the kind encouraged by the CAT can sustain entrepreneurship and business start-ups “by lifting credit constraints or providing the capital investment needed” (Arrondel and Masson Reference Arrondel and Masson2012, 133). Fifth and lastly, the existence of an upper limit on what one can receive creates an additional incentive to accumulate more through one’s own labor. Wealthy individuals who have already received the maximum allowed will want to earn more in order to be able to buy the share of their parents’ or relatives’ estate on which they may receive a preemption right. In the end, we have strong reasons to believe that the overall impact of the CAT on incentives to work should even be positive, while the impact of the AIT is slightly negative to nonexistent. The efficiency objection therefore rather favors the CAT over the AIT.
(c) Since even defenders of a market society have good reasons to mitigate the inequalities created by free markets through inheritance taxation (cf. supra), the last serious challenge to the CAT comes from right-libertarians who, following Murray Rothbard, claim that restricting free transfers is illegitimate because it clearly violates the right to private property. This objection is based on the idea that private property necessarily includes the absolute freedom to transfer one’s property. Any restriction on gifts and bequests is therefore illegitimate. However, it is unanimously agreed among philosophers and lawyers that private property is not an absolute right in the sense that it allows the owner to do everything she wants with her property. Rather, this right comes with many built-in qualifications to avoid that its use by some harms the legitimate interests of others (Haslett Reference Haslett1986, 140–41). To quote a classical example, the right Donald has on his baseball bat does not allow him to use it to smash Joe’s car. Similarly, the right to freely transfer property is only a prima facie right that is limited by several public interest restrictions. For example, it is illegal to give or bequeath property to a terrorist organization because its intended use is detrimental to the common interest. As any lawyer knows, many legal restrictions already limit the right to transfer property, and most of these restrictions are not problematic. The fallacy lies in considering the right to private property to necessarily include an unqualified right to freely transfer property. Rather, the right to private property is always and necessarily subject to further qualification by the law. Restrictions to the right to transfer property are not necessarily illegitimate if they are justified qualifications (Cappelen and Pedersen Reference Cappelen and Pedersen2018, 324–26), especially since, under the CAT, the owner retains the right to freely give, exchange, or bequeath her property within the limits stated by the quota.
The question then becomes: are the qualifications to the right to private property implied by the CAT legitimate? Given that the transfer of additional wealth to someone who has already received the amount authorized by the upper limit is detrimental to FEO, meritocratic values, democratic equality, and general utility, we have strong reasons to believe that they are legitimate. To assert the opposite position, one would have to argue that having an unqualified right to transfer property (to someone who has already received the maximum amount allowed) is morally more important than living in a democratic society whose structure promotes greater equality of opportunity and general utility while maintaining a connection between work, merit, and appropriation.
Moreover, these restrictions are even justified from the right-libertarian point of view since the reasons justifying the restrictions on bequests are in fact the same as those motivating the institution of private property. As Mill pointed out:
Private property, in every defense made of it, is supposed to mean, the guarantee to individuals of the fruits of their labor and abstinence. The guarantee to individuals of the fruits of the labor or abstinence of others, transmitted to them without any merit or exertion of their own, is not of the essence of the institution, but a mere incidental consequence, which, when it reaches a certain height, does not promote but conflicts with, the ends which render private property legitimate. (Mill Reference Mill and Robson1965b, 208)
The restrictions on the right to transfer generated by the CAT are ultimately justified by the same token as the principle of private property. The property objection therefore does not hold.
Conclusion
What makes a clear case in favor of the CAT is that, compared to the AIT, it better fulfills the four main reasons we have identified for taxing the transfer of wealth, and it is able to respond to the three principal objections. Moreover, the CAT sketched in this article is able to accommodate the social expectations that motivated the recent repeal of existing inheritance taxes in many countries (cf. the introduction): it is simpler than the AIT and its many loopholes, it spares the wealth accumulated in a lifetime of labor, it does not penalize new and alternative forms of families, and it will mostly affect the extremely wealthy who inherited their wealth in the first place rather than the working middle class. In other words, the CAT is both normatively superior to the AIT and better able to respond to social expectations about inheritance taxation.
Does this conclusion close the debate about inheritance taxation? Certainly not. Much work remains to be done to evaluate the CAT against other ways of taxing wealth transfers. At least three alternative options exist. The first is the complete abolition of inheritance, but it may be too radical to gain the support of public opinions in contemporary Western societies. The second is a reform of the AIT. Setting aside feasibility concerns and the remaining risk of loopholes, the AIT is however structurally less fair than the CATFootnote 13. A third alternative is the Rignano scheme (for a brief introduction, see Erreygers, Reference Erreygers, Erreygers and Vandevelde1997: 36–42). To put it shortly, the idea is to tax the transfer of wealth according to its “age,” i.e., to proportionate the tax rate to the genealogical distance between the creator of that wealth and its intended receiver. Following Daniel Halliday’s endorsement of the proposal (Halliday Reference Halliday2018), the Rignano scheme is gaining popularity among tax scholars. This proposal raises many concerns about feasibility but is certainly not impossible to implement, as recent discussions attest (Fleischer Reference Fleischer2020). More work should also be done to determine whether the Rignano scheme can, concretely, respond to the objections to inheritance taxation and assess whether it performs better or worse than the CAT on the various criteria discussed in this article.
This article provided an important contribution to the debate by sketching a “template” CAT and showing that, with these general parameters, it is more just than the AITFootnote 14. Much work remains however to be done to fine-tune this template and adapt it to the central values of each particular society. The plasticity of the CAT is actually another argument in its favor. Its architecture allows for an easy adaptation of its parameters to a society’s core values, eliminating the need for additional laws and parallel rules that increase legal complexity and create loopholes. For instance, if family values are a priority for a society, we could add a family house exemption of the kind described earlier. Conversely, if priority is given to FEO over family, one can lower the thresholds, cut the family house exemption, and allocate the tax revenue to a basic capital for all young adults. If economic efficiency is the priority, the thresholds can be raised to avoid interfering with economic incentives (while maintaining a cap to prevent dynastic wealth formation). If the priority given to private property makes setting a higher limit on what one can receive without working unbearable, the limit could be replaced by a highly progressive tax to discourage large wealth transfers and raise additional tax revenue for investments in predistribution policies. Properly designed, the CAT could also encourage the creation of new commons by giving municipalities a preemption right to buy the lands of deceased landlords or similarly support the creation of worker cooperatives by enabling employees to preemptively purchase shares of deceased owners. Many other variations, exemptions, and additional qualifications can be imagined to tailor the CAT closely to a society’s core values, thereby gaining the democratic support necessary to implement a tax on the right to receive wealth.
Data availability statement
This study does not employ statistical methods and no replication materials are available.
Acknowledgments
For comments and remarks on earlier versions of this paper, I would like to express my special thanks to Zahra Aboutalebi, Marie Bastin, Michel De Vroey, Axel Gosseries, Cécile Laborde, Justine Lacroix, Maxime Lambrecht, Hansong Li, Eric Nelson, Mélanie Plouviez, Jean-Yves Pranchère, Pierre-Etienne Vandamme, and Stuart White. I presented draft versions of this paper at the CSSJ Seminar in Oxford, the Harvard Political Theory Workshop, and the Philherit Seminar (online). I am grateful to the participants of these events for their questions, feedback, and suggestions. The taxation of inheritance is a lively topic, also beyond academia, and I wish to acknowledge the contribution of the many people – from close friends to taxi drivers – who offered honest feedback when commenting on what I thought would be a fair way of taxing inheritance. Last but not least, I would like to express my gratitude to three anonymous reviewers for their helpful suggestions and constructive comments.
Funding statement
This research was funded thanks to two grants by the Faculté de Philosophie et Sciences Sociales (Université libre de Bruxelles) and the Fonds National de la Recherche Scientifique (FRS-FNRS). I also enjoyed support from the Wiener-Anspach Foundation and the Belgian American Educational Foundation for research stays abroad. None of these fundings implied any conflict of interest.
Competing interests
There is no conflict of interest to report for this manuscript.
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