Murray and Wyden Target Billionaire Trusts, Introduce Landmark Legislation to Close Loopholes Sheltering Potentially Trillions in Untaxed Wealth

The Fair Trusts for Fiscal Responsibility Act cracks down on tax avoidance and ensures that millionaires and billionaires pay their fair share

A conservative estimate projects Murray's bill would generate $675 billion over ten years

Senator Murray: "The revenue from this bill alone could extend the ACA tax credits AND provide high quality child care for every working family in America."

Washington, D.C. - U.S. Senator Patty Murray (D-WA), Vice Chair of the Senate Appropriations Committee, introduced the Fair Trusts for Fiscal Responsibility Act of 2026 to close tax loopholes used by the wealthiest Americans to avoid paying taxes through complicated trust arrangements. The legislation is co-led by Senator Ron Wyden (D-OR), Ranking Member of the Senate Finance Committee.

"Firefighters and nurses don't get to hide their money in a trust fund and skip out on paying their taxes-billionaires shouldn't get to either," said Senator Murray. "The very wealthiest Americans hide their fortunes in a trust for generations and call it tax planning-that is absurd and those are dollars that should be going to our schools, infrastructure, and health care. In America, if you earn a paycheck, you are paying taxes-it's time to close the loophole that lets individuals with armies of lawyers stash away billions without paying taxes. This Republican Congress has bent over backwards to rig the system for billionaires. I am simply proposing that the ultra-wealthy-people with more than $50 million sitting in a trust-finally pay what they owe and contribute their fair share back to the country that made their success possible. I'll bet that most Americans would prefer we fund child care and pre-k for every working family in this country rather than let billionaires get a free ride on their taxes. The revenue from this bill alone could extend the ACA tax credits AND provide high quality child care for every working family in America. If you don't have more than $50 million laying around in a trust, you don't have to worry about this bill resulting in anything other than better funded roads and public schools."

"We cannot allow there to be ultra-wealthy dynasties in this country hoarding all the money and power for generations on end, and we cannot have a tax system that encourages it," said Senator Wyden. "Our budgets suffer and economic opportunity bleeds away when the ultra-wealthy dodge taxes in America, so this bill is a smart way of ensuring the highest earners are paying a fair share just like nearly everybody else."

Most Americans will not receive an inheritance, and for those that do, only those with assets exceeding $30 million-for a married couple-are required to contribute a portion through taxes, and even then, only on amounts over that substantial exemption. Fewer than 0.1% of Americans pay estate tax at all. These funds provide revenue that can be used for essential investments in our country, like schools or critical infrastructure. Yet many of the very wealthiest Americans use special trusts to delay, minimize, and avoid paying taxes. Experts estimate that hundreds of billions of dollars and potentially trillions of dollars are held in generation-skipping transfer tax exempt trusts that are not subject to the rule against perpetuities.

The Fair Trusts for Fiscal Responsibility Act addresses tax avoidance head on by applying a 1 percent rate on trust assets between $50 million and $100 million, 1.5 percent between $100 million and $250 million, 2 percent between $250 million and $1 billion, and 3 percent on assets above $1 billion. To ensure fairness, the bill provides full refundability of the withholding against estate tax liability so that only those actively avoiding transfer taxes face increased burdens, while also capping total withholding so it does not exceed estate tax owed. The legislation further strengthens compliance through new reporting requirements and penalties for noncompliance, while exempting charitable trusts, ERISA-qualified employee benefit trusts, and other trusts not typically used in estate planning.

A conservative estimate of a similar proposal indicates that Murray's legislation would raise approximately $675 billion over ten years, noting, "even based on our low-end estimate of $4.5 trillion in GST-exempt trusts today, if those trusts face an average annual tax of 1.5% under the withholding tax, that is approximately $675 billion over ten years." This could fund free school lunch for every kid in America, child care for every working family, and the replacement of every lead pipe in America; alternatively, the revenue could fund the Children's Health Insurance Program (CHIP) for decades, or extend the enhanced premium ACA tax credits nearly twice over.

In addition to Senators Murray and Wyden, the bill is also co-sponsored by Senators Van Hollen, Booker, and Alsobrooks.

The legislation is endorsed by Americans for Tax Fairness, Patriotic Millionaires, Public Citizen, Groundwork, Economic Security Project Action, NETWORK Lobby, National Women's Law Center, American Federation of State, County and Municipal Employees (AFSCME), Service Employees International Union (SEIU), American Federation of Teachers (AFT), and United for a Fair Economy.

"A tax system that favors the rich makes America a poorer country for everyone, including the rich themselves. Working Americans can't wait until later to pay taxes," said Bob Lord,Senior Vice President for Tax Policy, Patriotic Millionaires. "Taxes are withheld from every one of their paychecks. So when ultra-rich Americans use trusts to delay paying estate tax for 50 years on billion-dollar fortunes left for their grandchildren, average Americans feel cheated. Sen. Murray's Fair Trusts for Fiscal Responsibility Act would end this outrageous preferential treatment and restore a feeling of fairness to our tax system. Ultra-rich families wouldn't make more tax payments. They'd just make more timely tax payments, like the rest of America does."

"ATF applauds Senator Murray for introducing the Fair Trusts for Fiscal Responsibility Act," said David Kass, Executive Director of Americans for Tax Fairness. "For decades, the wealthy have been able to hoard massive amounts of wealth and pass it down to future generations through key loopholes. The existing estate-tax exemption is so high ($30M for married couples) that only the wealthiest 0.1% of estates owe any tax. Yet wealthy families can further reduce what they pay through strategies like GRATs and dynasty trusts, leading to losses in revenue for public investments in education, healthcare, and more. This legislation would make key reforms to curb these abuses and rein in dynastic wealth in our country."

Senator Murray is fighting for tax fairness and closing loopholes on Wall Street. Last month, at a Senate Budget Committee hearing on Social Security, Senator Murray slammed the Trump administration for gutting the Social Security Administration (SSA) and questioned witnesses on the fact that the very wealthiest Americans have the smallest effective payroll tax rate. Murray made clear that when it comes to addressing SSA solvency, there is no reason for working people to face drastic benefit cuts when the very wealthiest could simply pay their fair share.

In 2025, Senator Murray helped introduce the Carried Interest Fairness Act to eliminate a tax loophole that benefits wealthy money managers on Wall Street. The current carried interest loophole allows investment managers to often pay almost half the tax rate compared to most other Washington workers. Over the course of her career, Murray has long championed a fair tax system-rejecting Republican efforts to cut benefits for working people and repeatedly pushing for reforms to ensure the very wealthiest Americans simply pay their fair share. Murray has always recognized that the national debt and deficits pose real challenges; however, it has been her longstanding belief that America can reduce budget deficits while still investing in national priorities that support economic growth.

The full text of the legislation is HERE.

A one pager is HERE.

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