A tax system is progressive when households with greater capacity to pay contribute a greater share. The United States has not had a meaningfully progressive system in decades. Top statutory rates exist on paper, but the effective rate paid by the wealthiest households has trended toward — and below — what middle-class workers pay on their wages.
Building real progressivity is hard, and the difficulty is structural. Wealth that is never sold is never taxed. Income reclassified as capital gains pays a lower rate than income reclassified as wages. Assets held in trusts, foreign accounts, private partnerships, charitable shells, and dynastic vehicles disappear from the ledger. Every loophole is a route around progressivity, and the routes have multiplied faster than the rules that close them.
This layer is aimed at people. Ten instruments addressing the question — at the top of the income and wealth distribution, what counts as their income, and how do we make sure we count it. The structural layer is aimed at structures — corporate, consumption, institutional — and at the floor instrument that substitutes for FICA and the employer-paid health/dental/vision premium most employment packages already carry. Same architecture, different axis.
The ten mechanisms below do not stand alone. They are layered: each closes a specific avoidance route, and their disclosure obligations reinforce one another. False statement at any layer is independently tax fraud, and the disclosed records become the audit basis for every other instrument that touches the same base.
Today's payroll tax (FICA) catches paycheck wages reliably and almost nothing else. Bonuses partially. Equity vesting, exercised options, perks, deferred compensation, partnership distributions, platform income, and service income flow around it via timing, classification, and entity games. The Accord's Flat Payroll Tax puts every compensation form on the same footing — owed at a single 28% rate, uncapped, with substance governing treatment — so the form of payment does not determine whether the tax is due. The corporation's compensation declaration funds its own deduction; that same disclosure is the audit basis for the recipient's payroll-tax liability, the recipient's income-tax return, and — if applicable — the recipient's Estate Tax Prepayment Plan filing. False statement at any layer is independently tax fraud. (This section makes the recipient-and-base argument; the instrument itself — what it replaces and what it funds — is the structural layer's §1.)
Long-term investment retains preferential treatment for the middle class — the holding-period gradient (1-3 yr / 3-10 yr / 10+ yr) rewards genuine patience. But preferential rates are not free: above the $10M lifetime cap, capital gains converge to ordinary rates, and the convergence applies to total income above the cap regardless of holding period. The wealthy do not need a tax-policy nudge to invest. Above the cap, a dollar earned by clicking a mouse in a trading terminal is taxed the same as a dollar earned by sweating on a factory floor.
The top statutory rate climbs to settling-accounts territory on the comprehensive base — wages, bonuses, equity, options, deferred comp, partnership distributions, and (above the lifetime cap) capital gains. The top rate moves 1:1 with the payroll tax under the Debt Sunset Governor, in 0.25-percentage-point steps within the 49%–53% corridor. The corridor is statutory; the governor's actions are automatic.
Joint filing requires joint ownership
A married couple may claim the higher (2×) thresholds — Estate Tax Prepayment Plan, lifetime gift exemption, and any other instrument that scales with filing status — only by filing jointly with both spouses signing the return. The signed joint return constitutes a legally binding attestation that all marital assets are jointly owned. Because tax filings recur annually, the most recent jointly-signed return supersedes earlier instruments — including pre-nuptial agreements — on questions of asset ownership in divorce, probate, and any subsequent reconciliation against an undisclosed-asset finding. Couples who maintain segregated property either file separately or claim the single-filer threshold; the higher threshold is unavailable to them.
The architectural intent is to close the dynasty-recoalescence route by which a billionaire could nominally double the threshold while retaining sole control via a pre-nup. The election is voluntary and self-policing — the couple decides whether the doubled threshold is worth surrendering separate-property protection.
The mechanism is the existing tax-form signature line. No new registration system, no new Treasury process — the form already requires both signatures for joint filing, and the higher-threshold election adds an explicit jointly-owned-assets attestation to the same signature. Because the attestation is annual and dated, it is by construction the most recent statement of marital property ownership any court will see.
The Estate Tax Prepayment Plan is forward-collection of the eventual estate excise — Knowlton v. Moore (1900) settled estate transfers as an excise, not a direct tax requiring apportionment, and Congress's plenary authority over that excise has been undisputed since 1916. Every dollar paid against the prepayment credits against estate tax at transfer. The Plan serves three purposes simultaneously: (a) it generates current-year revenue; (b) it creates a catalog — a wealth holder must disclose possessions to satisfy the prepayment, and once that disclosure is made the basis for estate tax and capital-gains-at-death is established, every disclosed asset becoming a registered asset; and (c) it dampens the rate at which fortunes compound untaxed, both directly (the annual installment) and indirectly (capital-gains realization on shares sold to fund the prepayment). That dampening matters as policy because the larger the at-death liability grows, the stronger the late-life pressure to expatriate before it fires. Steady collection throughout life reduces the size of the eventual shock — and the pressure to flee the tax base in old age.
Brackets: 0.75% on $10M–$50M · 1% on $50M–$250M · 1.5% on $250M–$1B · 2% on $1B–$10B · 2.5% on $10B+. Threshold: $10M individual / $20M joint (joint requires the rule above). Disclosure window Year 1 rate: 0.8% on disclosed assets, no back tax, no penalties — the favorable invitation rate. Beyond Year 4, applicable rate + back tax + penalties; magnitudes deliberately unspecified by canon.
Closing the escape valves
A fair tax code fails if the largest fortunes can route around it. The Accord closes ten well-documented avoidance routes as a single architectural move — not because each is a separate policy debate but because each is a substance-over-form question with a known answer.
Today the basis of an inherited asset resets to fair-market value at death, erasing every dollar of unrealized appreciation permanently. This is the second exit door in buy-borrow-die: even if the holder pays nothing on the borrowing, heirs pay nothing on the appreciation. The Accord eliminates step-up. Death is a realization event; unrealized gains realize at transfer; the estate pays income tax on accumulated appreciation alongside estate tax on the post-tax wealth at transfer. The two extractions fire even when the Estate Tax Prepayment Plan has fully prepaid the estate-tax obligation.
Estate brackets are graduated: 32% on $10M–$50M · 37% on $50M–$250M · 42% on $250M+. The top bracket reflects the settling-accounts principle applied to fortunes accumulated during the century of unpriced externalities — wealth that grew while carbon, public-health, infrastructure, and worker-borne costs went uncollected. Estate Tax Prepayment Plan installments credit dollar-for-dollar against the estate at transfer. Disclosure during life converts the open-ended liability into a settled obligation; the prepayment is the path to settle quietly.
If gift-tax rates on transfers to organizations diverge from estate rates, rational donors exploit the gap and route wealth through tax-exempt entities they continue to control. The Accord enforces parity: gifts to any organization above the lifetime exemption are taxed at estate rates. Charitable institutions are no longer categorically tax-exempt above the wealth threshold — endowments, foundations, and donor-advised funds pay the institutional-investment excise on portfolios above threshold. Philanthropy at appropriate scale continues; the architecture rejects the premise that private charitable organizations do public good the government does not. US institutions providing security, resilience, and the continuity of constitutional democracy are public goods of equal standing, and concentrations of wealth benefit directly from them.
An asset hidden during life remains structurally bound to the estate it came from. HARO (Hidden Asset Recovery Office) statute reach is the life of the holder plus two generations of heirs, in rem against the asset and against the estate that bequeathed it. Discovery within that window brings the patriarch's estate back into scope for reconciliation — including distributions already made. Recovery is capped at the heir's total inheritance from this same patriarch's estate; the heir's own salary, home, savings, and inheritance from other family lines are unaffected. The estate-reach is what restores the patriarch's incentive to disclose during life: hiding doesn't just risk the hidden asset, it risks unwinding the entire planned bequest from the same estate. Magnitudes are deliberately unspecified — set by Treasury enforcement schedule. The unspecified open-ended liability is the architectural deterrent.
Layered defense, no single point of failure
Holding the position isn't free — the Estate Tax Prepayment Plan charges annually above the threshold. Selling pays the rate — capital-gains convergence applies above the lifetime cap. Dying doesn't escape — basis step-up is eliminated and unrealized gains realize at transfer. Hiding the asset is bounded — the disclosure window invites voluntary correction; declining-rate tapering plus two-generation estate-reach makes hiding asymmetrically dangerous. Recoalescing dynasty fortune through marriage requires actually pooling the assets.
No single instrument carries the full anti-avoidance load. That's the architecture, and that's why it can carry the rate increases the architecture also asks for.