Key provisions governing this calculation
- Estate Tax Prepayment Plan. The annual prepayment stops once cumulative payment equals the estate tax owed at current wealth. (How the prepayment works)
- Gift tax equals estate tax. Pre-death transfers incur gift tax at the estate-tax rate. No rate arbitrage between gifting and bequeathing. (Ch 9)
- Stepped-up basis eliminated. Death is a realization event; heirs inherit at date-of-death value only for working farms or operating businesses under the continuation election. (Ch 7)
- Working-farm continuation election. If heirs materially participate 15 years, capital gains deferred then forgiven; estate tax payable over 20 years. (Ch 9)
- Illiquid assets require external liquidity. Closely-held stock, dynasty-trust holdings, real estate — owner must provide cash from other assets or accept a commercial lien. (Ch 9)
- Disclosure window or broader estate reach. An undeclared asset bequeathed remains structurally bound to the estate it came from: discovery within two heir generations brings the estate's distributions back into scope for reconciliation, capped at the heir's total inheritance from the same estate. The heir's personal property and inheritance from other estates are unaffected. The cleaner path is the 36-month disclosure window: Year 1 at 0.8% lifetime on disclosed hard-to-discover assets (paintings, self-custody crypto, off-shore accounts), no back tax or penalties; Year 2 at 1.0% plus back tax (asset rolls into standard schedule); Year 3 at standard rates plus back tax (penalty-avoidance). After the window closes, standard rates plus back tax plus penalties plus compounded interest — with heir liability: undisclosed assets accrue interest and penalties to the heir as well as to the holder's estate when discovered.(Ch 9)(disclosure mechanics)
The Position
Self-made fortunes — founder equity, stock, crypto, business interests. Default 7% nominal growth models mature-portfolio compounding over a working life. The slider goes to 25% for hypergrowth scenarios (early-stage Tesla, early Amazon — the Musk / Zuckerberg / Bezos pattern). Same Accord tax treatment regardless of vehicle: realization on sale, CGAL lifetime cap, no stepped-up basis.
The Person
The Heir (v10.3 layer)
Lifetime cumulative accession the heir has already received from prior inheritances or large gifts (counts toward their accession-tax ledger). First $2M is exempt. Brackets (interim calibration): 10% up to $10M, 15% to $50M, 18% to $250M, 20% above.
Grandchild or further-removed recipient. GST (40% top) layers on the heir's accession in skip cases — the surcharge for bypassing the parent's settlement layer.
Founder equity (appreciation)
Today: $200M · Basis $200M · Unrealized $0· CGAL remaining $10.00MSection A
Position Lifecycle
Year-by-year evolution of this position from age 55 to age 90 under the Accord. Tracks one equity position only — multi-asset estates are typically modeled by running this calculator separately for each major position.
Position at start (age 55)
$200M
Position at death (age 90)
$1.11B
Cumulative prepayment paid
$263M
Eff. annual prepayment / avg position
1.14%
▸ Show year-by-year detail (36 years)
| Age | Price | Shares | Value | Projected ET | Status | Eff. prepay rate | Prepay paid | Cum prepay | CGT $ this yr | Eff. CGT rate |
|---|---|---|---|---|---|---|---|---|---|---|
| 55 | $200 | 991,000 | $198M | $81.50M | Active | 0.90% | $1.80M | $1.80M | — | — |
| 56 | $214 | 981,883 | $210M | $83.50M | Active | 0.91% | $1.92M | $3.72M | $30,379 | 23.8% |
| 57 | $229 | 972,659 | $223M | $85.63M | Active | 0.91% | $2.05M | $5.77M | $63,615 | 23.8% |
| 58 | $245 | 963,342 | $236M | $87.90M | Active | 0.92% | $2.18M | $7.95M | $99,811 | 23.8% |
| 59 | $262 | 953,889 | $250M | $90.33M | Active | 0.93% | $2.34M | $10.29M | $139,840 | 23.8% |
| 60 | $281 | 944,080 | $265M | $92.90M | Active | 0.96% | $2.56M | $12.85M | $187,960 | 23.8% |
| 61 | $300 | 933,945 | $280M | $95.61M | Active | 0.99% | $2.80M | $15.65M | $241,566 | 23.8% |
| 62 | $321 | 923,514 | $297M | $98.47M | Active | 1.02% | $3.05M | $18.70M | $300,773 | 23.8% |
| 63 | $344 | 912,817 | $314M | $101M | Active | 1.04% | $3.31M | $22.01M | $365,696 | 23.8% |
| 64 | $368 | 901,881 | $332M | $105M | Active | 1.07% | $3.58M | $25.60M | $436,453 | 23.8% |
| 65 | $393 | 890,734 | $350M | $109M | Active | 1.09% | $3.87M | $29.47M | $513,169 | 23.8% |
| 66 | $421 | 878,428 | $370M | $113M | Active | 1.11% | $4.17M | $33.65M | $1.01M | 37.0% |
| 67 | $450 | 865,892 | $390M | $118M | Active | 1.13% | $4.49M | $38.13M | $1.16M | 37.0% |
| 68 | $482 | 853,155 | $411M | $122M | Active | 1.15% | $4.81M | $42.94M | $1.33M | 37.0% |
| 69 | $516 | 840,245 | $433M | $127M | Active | 1.17% | $5.15M | $48.09M | $1.51M | 37.0% |
| 70 | $552 | 827,190 | $456M | $132M | Active | 1.19% | $5.50M | $53.60M | $1.70M | 37.0% |
| 71 | $590 | 814,014 | $481M | $137M | Active | 1.20% | $5.88M | $59.47M | $1.90M | 37.0% |
| 72 | $632 | 800,743 | $506M | $143M | Active | 1.22% | $6.26M | $65.74M | $2.12M | 37.0% |
| 73 | $676 | 787,401 | $532M | $149M | Active | 1.23% | $6.67M | $72.40M | $2.35M | 37.0% |
| 74 | $723 | 774,010 | $560M | $155M | Active | 1.25% | $7.09M | $79.50M | $2.59M | 37.0% |
| 75 | $774 | 760,592 | $589M | $162M | Active | 1.26% | $7.54M | $87.03M | $2.85M | 37.0% |
| 76 | $828 | 747,166 | $619M | $168M | Active | 1.27% | $8.00M | $95.03M | $3.12M | 37.0% |
| 77 | $886 | 730,496 | $647M | $176M | Active | 1.28% | $8.48M | $104M | $6.29M | 55.0% |
| 78 | $948 | 713,839 | $677M | $182M | Active | 1.29% | $8.94M | $112M | $6.85M | 55.0% |
| 79 | $1,014 | 697,224 | $707M | $189M | Active | 1.30% | $9.41M | $122M | $7.44M | 55.0% |
| 80 | $1,085 | 680,678 | $739M | $196M | Active | 1.31% | $9.90M | $132M | $8.06M | 55.0% |
| 81 | $1,161 | 664,225 | $771M | $203M | Active | 1.32% | $10.41M | $142M | $8.70M | 55.0% |
| 82 | $1,243 | 647,890 | $805M | $211M | Active | 1.32% | $10.93M | $153M | $9.37M | 55.0% |
| 83 | $1,330 | 631,694 | $840M | $219M | Active | 1.33% | $11.47M | $165M | $10.06M | 55.0% |
| 84 | $1,423 | 615,658 | $876M | $227M | Active | 1.34% | $12.03M | $177M | $10.79M | 55.0% |
| 85 | $1,522 | 599,798 | $913M | $236M | Active | 1.35% | $12.61M | $189M | $11.54M | 55.0% |
| 86 | $1,629 | 584,134 | $952M | $245M | Active | 1.35% | $13.21M | $202M | $12.31M | 55.0% |
| 87 | $1,743 | 568,577 | $991M | $254M | Active | 1.37% | $13.91M | $216M | $13.20M | 55.0% |
| 88 | $1,865 | 553,030 | $1.03B | $263M | Active | 1.39% | $14.76M | $231M | $14.24M | 55.0% |
| 89 | $1,996 | 537,531 | $1.07B | $273M | Active | 1.42% | $15.62M | $247M | $15.31M | 55.0% |
| 90 ✝ | $2,135 | 522,118 | $1.11B | $283M | Active | 1.44% | $16.51M | $263M | $16.41M | 55.0% |
| Lifetime totals | — | $263M | $175M | 51.0% | ||||||
| Wealth at death $1.15B → capital-gains tax, estate tax, prepaid-levy credit, and amount to heir spelled out in Estate settlement below. | ||||||||||
⟶ transfer to heir · ✝ death / estate settlement · Nominal growth 7%, inflation 2%, real ~5.0% · Status: Active = full-rate levy collected; Topup = capped to not overshoot projected estate tax; Suspended = cumulative prepayments already cover projected estate tax (no levy this year).
Section B
Estate Settlement at Death — under the Accord
What happens at death (age 90), treating the position as the entire estate. For multi-asset estates, calculate each position separately and sum.
Section C
Same Position — under Current Law
The same starting position, settled under today's federal estate-tax framework. Stepped-up basis at death eliminates capital gains; estate tax applies at 40 % above the $13.60M 2025-indexed exemption. Note: the position at death is larger than under the Accord because no shares are sold to fund a estate tax prepayment during life — the original 1,000,000 shares compound undiluted from $200M to $2.14B.
Position value at death$2.14B
Cost basis (stepped up to FMV)$2.14B
Capital-gains tax(step-up eliminates gain)−$0
Estate value subject to estate tax$2.14B
Less exemption (2025 indexed)−$13.60M
Taxable estate$2.12B
Estate tax (40 % top rate)−$849M
Heir receives (current law)$1.29B
In constant 1998 dollars$370M
Headline current-law top rate is 40 % above the exemption, but the actual collected rate on large estates averages ~12–15 % thanks to dynasty trusts, GRATs, life-insurance trusts, valuation discounts, and other planning. The Accord closes the gap between headline and collected by replacing the avoidance ecosystem with the estate-tax-prepayment installment + deemed-realization architecture.
Section 5
Comparison: Lifetime Tax Architecture
Reconciles totals across both architectures. The Accord substitutes continuous prepayment during life — credited dollar-for-dollar against the estate tax owed at transfer — for current law's deferred-lump-sum + step-up + dynasty-trust pattern.
| ACCORD | CURRENT LAW | |
|---|---|---|
| Position at death | $1.11B | $2.14B |
| Capital-gains tax at death — 55% top | −$556M | −$0 |
| Estate tax (gross) — 35/45/55/60% | −$274M | −$849M |
| Decedent's lifetime prepayment — 0.75/1/1.5/2/2.5%/yr | +$274M | — |
| Net estate tax owed at death | −$0 | −$849M |
| Accession tax (heir) — 10/15/18/20% (interim) | −$105M | — |
| Heir receives | $455M | $1.29B |
| In constant 1998 dollars | $131M | $370M |
| Total federal tax | $1.10B | $849M |
| Effective rate (lifetime) | 78.71% | 39.75% |
Effective rate = 1 − (heir receives ÷ un-eroded position at death). This captures both federal collections AND the foregone compounding from shares sold during life to fund the prepayment — the household's full take-rate, not just direct tax collected. Under current law there are no share sales, so its rate equals federal tax ÷ position.
Yes, current law leaves more for heirs — that's exactly the story. The position at death under current law is larger because no shares were sold to fund a estate tax prepayment during life. The estate tax that hits at death only applies above the $13.60M exemption at 40 % nominal, and dynasty trusts / GRATs / step-up basis collapse the collected rate to ≈12–15 %. The rates have been low and the avoidance ecosystem deep for decades, which is why concentrated wealth has compounded at the top of the distribution faster than productivity, faster than wages, and faster than the public revenue base could keep up with. The Accord's architectural choice — continuous, predictable taxation during life rather than deferred lump-sum at death susceptible to basis games — closes that gap by collecting in installments instead of relying on a one-time event the avoidance ecosystem has had 40 years to engineer around.
Yes, current law leaves more for heirs — that's exactly the story. The position at death under current law is larger because no shares were sold to fund a estate tax prepayment during life. The estate tax that hits at death only applies above the $13.60M exemption at 40 % nominal, and dynasty trusts / GRATs / step-up basis collapse the collected rate to ≈12–15 %. The rates have been low and the avoidance ecosystem deep for decades, which is why concentrated wealth has compounded at the top of the distribution faster than productivity, faster than wages, and faster than the public revenue base could keep up with. The Accord's architectural choice — continuous, predictable taxation during life rather than deferred lump-sum at death susceptible to basis games — closes that gap by collecting in installments instead of relying on a one-time event the avoidance ecosystem has had 40 years to engineer around.
Canonical basis: Blueprint v10.2 Chapter 9. All values nominal; real purchasing power erodes at the specified inflation rate. Estate tax and gift tax rates match at every transfer point. Working-farm continuation requires 15-year material participation (500+ hours/year). Calculator uses canonical parameters only — results may shift when CBO dynamic scoring is complete.
Disclosed assets only · 36-month onboarding window + heir extension
This calculator models disclosed assets only. The architecture opens a 36-month onboarding window with year-by-year tapering benefit for previously-hidden assets in eligible categories — foreign financial holdings, foreign physical assets, privately-held art and collectibles, cryptocurrency cold storage, and similar genuinely-hard-to-detect-without-cooperation assets:
Year 1 (Months 1–12). Disclosed assets pay 0.8%. No back tax. No penalties. The Year 1 rate is the architecture's invitation to come forward.
Year 2 (Months 13–24). Disclosed assets pay 1.0%, plus retrospective back tax (with applicable interest) for the period the asset was held undeclared. No penalties.
Year 3 (Months 25–36). Standard graduated bracket rates apply, plus back tax. No penalties — this remains a penalty-avoidance window. No rate concession.
Year 4 onward (after the window closes). Standard rates plus back tax plus applicable penalties. Penalty magnitudes are set by Treasury enforcement schedule, not specified in canon — the open-ended liability is the architectural deterrent. HARO involuntary discovery applies if assets are found via investigation, whistleblower, or analytics.
Estate reach. An undeclared asset bequeathed remains structurally bound to the estate it came from. Discovery within two heir generations brings the estate's distributions back into scope for reconciliation, capped at the heir's total inheritance from the same estate. The heir's personal property — earnings, their own home, inheritance from a different family line — is unaffected. Magnitudes are set by Treasury enforcement schedule.
The estate tax prepayment is an annual top-up: each year's payment is the smaller of the full statutory rate or the gap between cumulative prepayments and current-year projected estate tax. Most years collects the full statutory rate; some years caps at the residual gap; years where cumulative already covers projected ET have a zero top-up — same continuous formula throughout, the Plan is never “suspended”. Prepayments accumulate in nominal dollars — they do not earn interest, exactly like income-tax withholding or quarterly estimated tax. Volatility excess at death (when prepayments exceed actual estate tax owed) becomes a basis credit on inherited assets — not a refund, not forfeiture.
Full disclosure architecture and HARO enforcement specifications documented in Blueprint Chapter 22.
Year 1 (Months 1–12). Disclosed assets pay 0.8%. No back tax. No penalties. The Year 1 rate is the architecture's invitation to come forward.
Year 2 (Months 13–24). Disclosed assets pay 1.0%, plus retrospective back tax (with applicable interest) for the period the asset was held undeclared. No penalties.
Year 3 (Months 25–36). Standard graduated bracket rates apply, plus back tax. No penalties — this remains a penalty-avoidance window. No rate concession.
Year 4 onward (after the window closes). Standard rates plus back tax plus applicable penalties. Penalty magnitudes are set by Treasury enforcement schedule, not specified in canon — the open-ended liability is the architectural deterrent. HARO involuntary discovery applies if assets are found via investigation, whistleblower, or analytics.
Estate reach. An undeclared asset bequeathed remains structurally bound to the estate it came from. Discovery within two heir generations brings the estate's distributions back into scope for reconciliation, capped at the heir's total inheritance from the same estate. The heir's personal property — earnings, their own home, inheritance from a different family line — is unaffected. Magnitudes are set by Treasury enforcement schedule.
The estate tax prepayment is an annual top-up: each year's payment is the smaller of the full statutory rate or the gap between cumulative prepayments and current-year projected estate tax. Most years collects the full statutory rate; some years caps at the residual gap; years where cumulative already covers projected ET have a zero top-up — same continuous formula throughout, the Plan is never “suspended”. Prepayments accumulate in nominal dollars — they do not earn interest, exactly like income-tax withholding or quarterly estimated tax. Volatility excess at death (when prepayments exceed actual estate tax owed) becomes a basis credit on inherited assets — not a refund, not forfeiture.
Full disclosure architecture and HARO enforcement specifications documented in Blueprint Chapter 22.
Foundations and Institutions · A tax on tax-exempt equity
Institutional Investment Excise
Tax-exempt institutions — university endowments, private foundations (including family-controlled), religious endowments, hospital systems, museums — pay an annual excise on investment assets above the $5M deduction and a 24-month operating-reserve safe harbor. Mission-deployed assets (campuses, hospitals, houses of worship, equipment in use) are exempt. The rate is one-third of the lower of trailing 2-year and 5-year real S&P 500 total return, floored at zero. The institution always keeps two-thirds of real growth.
Institution type
Investment assets ($)
Annual op. expenses ($)
Real S&P return (4.2%)
Nominal growth (7.0%)
Mission spend (5.0%)
Operating reserve (exempt)
$11.00B
24 mo of op expenses
Year-1 taxable base
$38.99B
after $5M deduction + reserve
Prevailing rate
1.40%
real return ÷ 3, floored at 0
Year-1 excise
$546M
continuous, no realization event
10-yr cumulative excise
$5.75B
avg eff. 1.104% / yr
| Year | Investment assets | Op reserve | Taxable base | Annual excise | Mission withdrawal |
|---|---|---|---|---|---|
| 1 | $50.00B | $11.00B | $38.99B | $546M | $2.50B |
| 2 | $50.45B | $11.00B | $39.45B | $552M | $2.52B |
| 3 | $50.91B | $11.00B | $39.91B | $559M | $2.55B |
| 4 | $51.37B | $11.00B | $40.37B | $565M | $2.57B |
| 5 | $51.83B | $11.00B | $40.83B | $572M | $2.59B |
| 6 | $52.30B | $11.00B | $41.29B | $578M | $2.61B |
| 7 | $52.77B | $11.00B | $41.76B | $585M | $2.64B |
| 8 | $53.24B | $11.00B | $42.23B | $591M | $2.66B |
| 9 | $53.71B | $11.00B | $42.70B | $598M | $2.69B |
| 10 | $54.19B | $11.00B | $43.18B | $605M | $2.71B |
Rate examples by market condition — the “lower of two windows” rule (2-year vs 5-year trailing) ensures institutions get the more favorable rate in all market conditions. After a crash, the 2-year window drops faster, lowering the rate during recovery. During a bubble, the 5-year window restrains the rate when valuations are stretched.
Strong bull (sustained 12% real)
4.00% rate
Above average (8% real)
2.67% rate
Historical average (4.2% real)
1.40% rate
Weak (2% real)
0.67% rate
Crash / stagnation (≤0%)
0.00% rate
The same rule applies universally — Harvard, the Gates Foundation, a community foundation, a megachurch, a small Presbyterian church with $200K in savings (well below threshold, $0 owed). One rate, one threshold, one rule for all institutions. This single instrument replaces several earlier proposed mechanisms that were rejected through iteration: the 50-year deemed-realization rule on dynasty trusts and foundations (unenforceable), EPL inclusion of family-foundation assets in the founder's estate-tax-prepayment calculation (constitutionally fragile), fixed-rate excises on large endowments only (threshold gaming), and fixed rates above $1B (fractionation incentive). The continuous excise resolves all four issues at once — and runs in parallel to the individual estate-tax-prepayment track without termination at death and without crediting against estate tax.
The Civilization Premium
The case for staying
The Accord invests in infrastructure that no tax haven replicates. For high earners, the math favors staying. If you're earning $500K+ or managing $5M+ in assets — the 40% exit tax creates a 2-15 year break-even horizon. Beyond that: hardened grids, phased trauma-access improvement, pandemic readiness, the deepest capital markets, and the strongest courts.
Architecture version: v10.2
Scoring version: v10.2 (rerun 2026-04-30)