Article: Closing the Gaps: Comprehensive Anti-Abuse Provisions for the Generational Benchmark Inheritance Regime

The Generational Benchmark Inheritance Regime (GBIR) distinguishes between passive market returns (Beta) and active value creation (Alpha) in wealth transfer taxation. This paper addresses the critical question of operational feasibility by cataloging twelve potential evasion strategies and proposing specific anti-abuse provisions to neutralize each. The edge cases span five categories: intra-family wealth leakage, trust and entity structures, spousal planning, asset manipulation, and cross-border arbitrage. Without comprehensive safeguards, the regime’s estimated $295 billion annual revenue would collapse to $120-150 billion. We prioritize provisions into three tiers by revenue risk: Tier 1 (existential threats requiring statutory inclusion), Tier 2 (significant risks addressable through statute or regulations), and Tier 3 (moderate risks manageable through regulatory guidance). The paper demonstrates that the GBIR’s discrete valuation windows avoid the administrative infeasibility that plagues continuous wealth taxation, and that the regime can achieve both substantial revenue collection and powerful incentives for productive capital deployment if properly fortified against abuse.