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我是戴恩·布鲁格勒。
I'm Dane Brugler.
我为《The Athletic》报道NFL选秀。
I cover the NFL draft for The Athletic.
我们的选秀指南因为包含了海量信息而被命名为《The Beast》。
Our draft guide picked up the name The Beast because of the crazy amount of information that's included.
我正在查看成千上万的球员,并撰写数百份球探报告。
I'm looking at thousands of players putting together hundreds of scouting reports.
从去年的选秀开始,我就一直在跟进今年的选秀。
I've been covering this year's draft since last year's draft.
《The Beast》里有很多内容是你在其他地方根本找不到的。
There is a lot in the beast that you simply can't find anywhere else.
这是《The Athletic》和《纽约时报》提供的那种深入且独特的新闻报道。
This is the kind of in-depth, unique journalism you get from The Athletic and The New York Times.
你可以在 nytimes.com/subscribe 订阅。
You can subscribe at nytimes.com slash subscribe.
4月15日,正如你所知,是美国的报税日。
April 15 was, as you may know, tax day here in The US.
如果你是一个普通的美国人,靠工资赚钱,这可能不是你一年中最喜欢的一天。
If you're a normal American, you make money through wages, probably not your favorite day of the year.
如果你的收入处于中位数或以上,你得把相当多的钱交还给政府。
If you make a median income or above, you're handing a lot of that money back to the government.
但这就是我们生活在社会中所付出的代价。
But that is the price we pay for living in a society.
对吧?
Right?
但并不是对每个人都是这样。
Well, not for everyone.
你可能还记得这件事。
You may remember this.
2021年,ProPublica发布了一项调查,基于一批泄露的税务文件,揭示了最富有的美国人实际缴纳或未缴纳的税款。
In 2021, ProPublica published an investigation built on a bunch of leaked tax documents revealing what the richest Americans really pay or don't.
沃伦·巴菲特的实际税率仅为0.1%。
Warren Buffett had a true tax rate of point one percent.
杰夫·贝佐斯为0.98%。
Jeff Bezos, point 98%.
迈克尔·布隆伯格为1.3%。
Michael Bloomberg, 1.3%.
我们无法每年看到他们的纳税文件,但大致能知道他们是如何操作以及其中的机制的。
Now we don't get to see their tax documents year on year, but what they're doing, we kinda know what it is and how it works.
那么,这究竟是什么?它是如何运作的?我们又能做些什么来改变它?
So what is it, and how does it work, and what can we actually do about it?
雷·马多夫是波士顿学院法学院的教授,专攻税法和遗产规划,著有《第二遗产:税法如何造就美国贵族阶层》。
Ray Madoff is a professor at Boston College Law School who specializes in tax law and estate planning and is the author of The Second Estate, How the Tax Code Made an American Aristocracy.
她深知税制的弊端,部分原因在于她曾帮助富人利用这套体系,同时也提出了一些改革建议。
She knows how broken the tax system is, partially because she has helped the rich navigate it, and she has some ideas for how to fix it.
一如既往,我的邮箱是EzraKleinchow@nytimes.com。
As always, my email, EzraKleinchow@nytimes.com.
雷·马多夫,欢迎来到节目。
Ray Madoff, welcome to the show.
非常感谢你,伊扎。
Thanks so much, Ezra.
很高兴能来这里。
Wonderful to be here.
纳税日刚过。
So tax day just passed.
我们很多人在最后几天都在忙着报税,不过我就不点名了。
A lot of us were doing our taxes here in the final couple of days, not naming any names.
但让我们从这里开始。
But let's start here.
如果你是个普通人,你会交哪些税?
If you're a normal person, what kind of taxes do you pay?
你要交很多税。
You pay a lot of taxes.
关键是这样。
Here's the thing.
美国人,无论谁有工作,无论是为自己还是为他人工作,都要缴纳相当可观的税款。
Americans, anyone who has a job or anyone who works for a living either for themselves or for others, pays significant taxes.
他们缴纳的所得税税率最高可达37%。
They pay income taxes at rates up to 37%.
此外,他们还要缴纳高达15.3%的工资税,加在一起,税负相当沉重。
In addition, they pay payroll taxes that are as high as 15.3%, and together, it's a pretty significant liability.
这意味着,高收入的美国人缴纳了大量税款,而所有收入阶层的美国人都要缴税。
So what this means is that high earning Americans pay lots and lots of taxes, but all earning Americans pay something in taxes.
这和人们可能听过的统计数据如何吻合呢?据说我们的税制非常、非常累进,甚至荒谬地累进:40%的人不缴纳任何所得税,而前1%的人却缴纳了40%的所得税。
How does this fit with the statistic people might have heard, which is that in this telling, our tax code is very, very progressive, almost ridiculously so, that 40% of people pay no income taxes, and then the top 1% pay 40% of the income taxes.
当你听到这种说法时,会觉得这简直是个‘劫富济贫’的税制。
When you hear that, that sounds like a very soak the rich kind of code.
没错。
Absolutely.
这个统计数据的问题在于,它在两个方面都具有误导性。
And the problem with that statistic is it's misleading on both ends.
让我们先从那40%不缴税的人说起。
So let's start first with the 40% of non payers.
你可能听说过米特·罗姆尼谈论过47%这个数字,那是他竞选时的情况,当时他被偷录到说:47%的美国人不缴税,因此他们永远不会投我,因为他们只是索取者,不是创造者。
You might have heard this in terms of Mitt Romney talking about the 47%, which is what it was when he was running for office and he was caught on a hot mic saying, 47% of Americans are nonpayers, and therefore, you know, they'll never vote for me because they're just takers, not makers.
他没有考虑到的是,工资税所带来的沉重负担。
The thing that he didn't account for is the tremendous burden imposed by payroll taxes.
尽管40%的美国人不缴纳任何所得税,但他们仍然要缴纳可观的工资税。
And even though 40% of Americans don't pay any income taxes, they still pay significant payroll taxes.
事实上,我刚刚读到一个数据:80%的美国人缴纳的工资税比所得税还要多。
Indeed, today, I just read a statistic that 80% of Americans pay more in payroll taxes than they pay in income taxes.
这些税负可能相当沉重,因为与所得税不同,工资税从第一美元就开始征收。
And these can be quite burdensome because unlike income taxes, they start at dollar 1.
所以,关于不缴税人群的说法是错误且具有误导性的。
So, was wrong and misleading in terms of the non payers.
但当涉及到最顶层的1%时,这种说法尤其具有误导性。
But where it's particularly misleading is when it comes to this top 1%.
每当有人提议对富人征收更多税时,我们总能看到这种情况。
We see this all the time whenever there are movements to impose more taxes on the wealthy.
《华尔街日报》、《华盛顿邮报》、《经济学人》等媒体纷纷开始刊登相关报道。
The stories start popping up in The Wall Street Journal, The Washington Post, The Economist.
这些报道都只是在过去几个月内出现的。
Those are just in the past couple of months.
它们都问:你在说什么?
They all say, what are you talking about?
最顶层的1%已经缴纳了40%的所得税。
The top 1% are already paying 40% of the income taxes.
但这一统计数字没有涵盖的是,它所指的是收入最高的1%,即那些高收入的律师、医生和金融从业者。
And what this isn't capturing is that that statistic is referring to the top 1% of income earners, those with the most income, high income lawyers, doctors, finance people.
他们确实缴纳了很大一部分的所得税。
They indeed are paying a significant chunk of the income taxes.
然而,谈到最富有的美国人,比如扎克伯格、贝索斯、马斯克、埃里森,我们经常听到的这些人,他们成为不缴税者(占40%)的可能性,与成为纳税前1%者的可能性一样大。
However, when it comes to the wealthiest Americans, the Zuckerberg, Bezos, Musk, Ellison, all the people we hear about so often, they are just as likely to be in the 40% of nonpayers as they are in the top 1% of payers.
这是因为,在我们现行的税收制度下,他们可以通过避免产生应税收入来完全规避纳税义务。
And that's because under our current tax system, they are able to avoid taxes altogether by avoiding taxable income.
那你给我详细讲讲吧。
So walk me through this.
你就是埃隆·马斯克或者杰夫·贝索斯。
You're Elon Musk or Jeff Bezos.
恭喜你。
Congratulations.
谢谢。
Thank you.
你交哪些税?
What kind of taxes do you pay?
你不交哪些税?
What don't you pay?
当你成为杰夫·贝佐斯或埃隆·马斯克时,怎么可能不交所得税呢?
How do you end up not paying income taxes when you're Jeff Bezos' Elon Musk?
你在说什么?
What what are you talking about?
首先,我们先聚焦杰夫·贝佐斯,因为他的情况更典型。
So first of all, let's focus on Jeff Bezos because he's much more of a classic case.
对吧?
Right?
对于杰夫·贝佐斯来说,他创办了自己的公司。
For Jeff Bezos, he started his own business.
他拥有相当大比例的股票。
He owns, you know, a a dominant amount of the stock.
多年来,他的年薪从未超过8.2万美元,已经二十多年了,他的工资始终被限制在8.2万美元。你可能会问,为什么会这样?
And over the course of the years, he has taken a salary that is no higher than $82,000 It's been over twenty years now, and that's his salary is always capped at $82,000 And you might say, well, why would it be?
他创办了这家公司。
He started the company.
他就是这个人。
He's the man.
他为什么不开一个高额工资来反映他投入公司的所有资金呢?
Why isn't he taking a huge salary to reflect all of debt he put into the company?
因为工资是给傻瓜的。
And the reason is because salaries are for suckers.
当人们拿工资时,他们需要缴纳高额的所得税和工资税。
When people take a salary, they are subject to high income taxes and payroll taxes.
杰夫·贝佐斯和我们其他许多亿万富翁都不想缴纳这些税。
And Jeff Bezos and a lot of our other multi billionaires have no interest in paying those taxes.
所以,他们通过股票价值的增长来获取收益,而他们的股票价值已经大幅增长。
So instead, they take their benefits through the growing value of their stock, and their stock has grown enormously.
在我们现行的制度下,这种股票的巨额增长完全免税,且没有任何时间限制,这些股票永远不会被征税。
And that massive growth of stock happens entirely tax free with no time frame under our current system in which that stock will ever be subject to tax.
这是因为我们只在股票被卖出时才征税。
And that is because we only impose a tax if the stock is sold.
贝索斯从来不需要出售股票,因为他可以直接以股票为抵押借款,用这笔钱来维持他的生活方式,并支付贷款产生的利息。
And Bezos never has to sell the stock because he can simply borrow against the stock and use that money to support his lifestyle and to pay any interest that's due on the loan.
我想放慢一点,因为这个回答包含了很多内容。
So I wanna slow this down because there's a lot in that answer.
让我先说说‘薪水是给傻瓜的’这句话。
Let me start with salaries are for suckers.
你经常会听到一种说法,那就是:不。
One thing that, you know, you'll hear is that no.
不。
No.
不。
No.
他们并不是在逃避薪水。
They're not avoiding a salary.
他们所做的,是确保自己的利益与公司保持一致。
What they're doing is making sure their interests are aligned with the companies.
你知道,不管公司发生什么,你都会拿到薪水,但贝索斯只有在股价上涨时才能赚钱。
You know, you get a salary kinda no matter what happens in the company, but Bezos only makes money if a stock goes up.
所以这是出于公共精神。
So this is public spirited.
你知道,埃隆·马斯克有时一年只拿一美元。
You know, Elon Musk sometimes making, like, a dollar a year.
这些是将自身利益与公司实际成功绑定的具有公共精神的首席执行官,我们应该为此称赞他们。
That these are public spirited CEOs who have yoked themselves to actual success, and we should applaud them for it.
这种用股票而非薪水支付自己报酬的方式,在激励机制上对所有人都更好。
That this paying themselves in stock is just better for everybody, incentives wise, than salary.
你为什么不认同这一点呢?
Why don't you buy that?
因为这并不真实。
Because it's not true.
我的意思是,真实的情况是,他们通过股票获利。
I mean, what is true is that they are profiting through their stock.
可以说,这与他们的利益一致,但他们也可以拿薪水。
Arguably, it aligns with the interest, but they could be taking a salary too.
这对公司来说是可以抵税的。
It would be deductible to the company.
并没有任何实质证据表明这才是他们这样做的真正原因。
There's nothing that really supports that that's the actual reason for doing so.
所以,是的,这听起来是个不错的借口,但我认为没人会一本正经地这么说。
So, yes, it's a nice cover story, but I don't think anybody presents it with a straight face.
我觉得这听起来像是我们只是随机挑选了一些富人,比如杰夫·贝索斯和埃隆·马斯克。
I think it can sound like we're just picking rich people at random, Jeff Bezos, Elon Musk.
但2021年ProPublica发布的一项调查基于实际泄露的税务文件,让我们真正了解了他们的税务情况。
But there's this 2021 investigation published by ProPublica that came from actual leaked tax documents that gave us a real window into them.
我们确实知道他们实际缴纳了多少税。
We actually know what they paid.
是的。
Yeah.
你能跟我讲讲这个调查吗?我们实际看到了什么,从中了解到了什么?
Can you tell me about that investigation, what what we actually saw and learned from that?
是的。
Yeah.
有一位名叫查尔斯·利特尔约翰的人。
So there was a fellow by the name of Charles Littlejohn.
那就是他的真名。
That was his actual name.
取自狄更斯笔下的人物。
Named by Dickens.
对,就是罗宾汉那个角色。
By, yes, the Robin Hood character.
他是国税局的一名承包商,看到了这些纳税申报表,并将它们泄露给了ProPublica。
And he was a contractor at the IRS, and he saw all of these tax returns, and he leaked them to ProPublica.
他现在实际上正在坐牢。
He's actually in jail now.
他被发现后受到了非常严厉的监禁判决,因为有许多非常富有、有权势的人对此感到非常愤怒
He was hit with a very significant prison term when they found him because there were a lot of very rich, powerful people who were quite angry
关于这个,非法之处在于
about Well, it is illegal to
这绝对是非法的。
was absolutely illegal.
这是非法的,但实际的处罚远比他所受到的要轻得多。
It was illegal, but the actual penalty was much smaller than what he actually got.
这些信息之所以如此重要,是因为税务学者长期以来都知道,富人可以通过避免应税收入来避税。
And the reason this information was so important is because, well, tax scholars long knew that there were ways for wealthy people to avoid taxes by avoiding taxable income.
对吧?
Right?
领取低工资,不出售他们的股票。
Taking low salaries and not selling their stock.
人们一直对此持怀疑态度,认为这仅仅是理论上的。
It was always met with, that's just theoretical.
这并不真实。
That's not real.
但当这些纳税申报表被泄露时,就不再是理论了。
But here, when these tax returns were leaked, it was no longer theoretical.
这是许多最富有的美国人缴纳零税款的纳税申报表。
It was tax returns of many of our richest Americans paying zero in taxes.
因此,现在人们再也无法说这只是理论了,因为我们知道事实并非如此。
And so now it's no longer possible for people to say it's just theoretical because we know that it's not.
我的意思是,这项调查发现,那一年沃伦·巴菲特的实际税率是0.1%,杰夫·贝佐斯是0.98%,迈克尔·布隆伯格是1.3%。
I mean, that that investigation found that year that Warren Buffett had a what they called the true tax rate of point 1%, Jeff Bezos point 98%, Michael Bloomberg 1.3%.
我的意思是,我交的税比这高多了。
I mean, I pay much higher taxes than that.
我的意思是,他们在这里捕捉到的当然是他们股票的未实现收益。
I mean, what of course, what they're capturing there is their unrealized gains on their stock.
那么你讲的故事的下一部分,出售股票来资助你的生活方式有什么不同?
Then the the next part of the story you're telling, what is the difference between selling stock to fund your lifestyle?
杰夫·贝佐斯和埃隆·马斯克,他们 presumably 拥有私人飞机、多处房产和奢华的度假。
Jeff Bezos and Elon Musk, they presumably have private planes and multiple homes and fancy vacations.
那么,通过出售股票来资助这些开销,和你刚才说的以股票为抵押借款来资助,这两者之间有什么区别呢?
And what is the difference between funding that by selling stock and funding it by what you just described, which is borrowing against stock?
如果他们出售股票,就必须做两件事。
If they were to sell the stock, then they would have to do two things.
第一,他们需要缴纳资本利得税,算上所有相关税项,税率超过23%。
One is they would have to pay capital gains taxes, which would be when you take into account all the taxes associated with it over 23%.
所以这比在
So that's lower than on a
高收入情况下缴的税要低。
high income.
当然。
Absolutely.
出售股票显然比拿工资要划算得多。
Selling the stock is definitely a better play than having to take a salary.
所以工资真是傻瓜才拿的。
So because salaries suckers.
结果发现卖股票也是傻瓜才做的事,只是没那么傻罢了。
And are it turns out selling stock is for suckers too, but just slightly less of a sucker.
所以你能享受比拿工资更低的税率。
So you get to pay lower tax rates than you would on your if you were to take a salary.
你不需要缴纳工资税,只需要缴纳净投资税,而且税率更低,还有20%的资本利得税率。
Your payroll taxes are you don't have payroll taxes, you just have this net investment tax, which is less, and you have a 20% capital gains rate.
这比工资好,但还是不如以股票作抵押借款。
So that's better than salaries, but not as good as borrowing against the stock.
所以你可能会去找一家私人贷款机构。
So you go to a private lender probably.
你知道,你也可以去银行,但银行最大的风险是借给一个会违约的人。
You know, you could go to a bank, and their biggest risk is that they're gonna lend it to somebody who is gonna default on the loan.
但如果你借钱给杰夫·贝佐斯,他用亚马逊股票和其他资产作为贷款抵押,这笔贷款违约的风险几乎为零。
But if you're lending it to Jeff Bezos and he's giving you Amazon stock and other assets to hold as collateral against the loan, the risk of that loan going unpaid is nil.
所以他们本质上是在提供一笔无风险贷款,提供非常优惠的利率,但仍能从中获利,因为他们的业务就是放贷。
So they are basically making essentially a risk free loan for which they offer very favorable rates, and still they profit from it because the business is to lend money.
但关键是,当我们转向贝索斯这一方时,巨大的优势在于这笔贷款完全是免税的。
But the thing is, when we turn to Bezos' side, the tremendous advantage is that that loan is entirely tax free.
所以当他拿到这笔钱去买游艇时,并没有发生应税事件。
So when he gets that money and buys his yacht, he has not had a taxable event.
他仍然拥有他的亚马逊股票。
He continues to own his Amazon stock.
他继续过着奢华的生活方式,而他所需要做的,就是每年支付一点点利息。
He continues to be able to live the lavish lifestyle, and all he has to do is, you know, pay a little bit in interest every year.
我想再打断你一下。
I wanna stop you again on this.
他们根本不需要偿还贷款,这真的不太符合直觉。
They don't need to pay back the loans because this really doesn't feel intuitive.
怎么可能靠这些贷款来维持奢华的生活方式,却从来没有人还钱呢?
Like, how is it possible to fund a lavish lifestyle on these loans and and no one ever has to pay them back?
对吧?
Right?
理论上,总有一天贷款会到期。
At some point in theory, the loan comes due.
不,不是这样的。
Well, no.
你假设贝索斯生活在普通美国人那样的世界里,他们有二十年的房贷,银行借钱出去是指望收回本金的。
You're assuming that Bezos lives in the world of Americans who have, like, twenty year loans on their homes, and the bank is lending the money, counting on getting the money back.
这些放贷的人本身就是做放贷生意的,他们很乐意一直继续放贷。
These are people lending money in the business of lending money, and they are happy to keep lending money.
如果你做的是放贷生意,钱收回来之后,就得再找别人借出去。
It's if you're in the business of lending money and you get the money back, then you have to find somebody else to lend it to.
那为什么不直接一直贷给贝索斯呢?
So why not just keep lending it to Bezos?
所以你是说,你用这种方式资助生活方式——一个贷款接一个贷款,有时用新贷款还旧贷款,就这样反复循环?
So you're just taking out in in this way of funding a lifestyle, one loan after another, sometimes paying one loan back with another, and you're just doing this again and again?
是的。
Yeah.
我认为难以理解的是,当一个人拥有一万亿美元、两万亿美元,甚至接近八千亿美元的财富时,这究竟意味着什么。
I think what's hard to internalize is how much wealth it really is when somebody has a $100,000,000,000, $200,000,000,000, almost $800,000,000,000.
但当涉及到贝索斯这样的亿万富豪和其他百亿美元富豪时,他们并没有触及到自己全部资产的价值。
But when it comes to somebody like Bezos and our other centibillionaires, they are not bumping up against the value of their entire assets.
对吧?
Right?
几十亿美元足以支撑相当舒适的生活方式,他们根本不需要接近那些可能无法提供足够抵押品的风险边缘。
A few billion really supports quite a lovely lifestyle, and they don't have to get anywhere near where there's some risk that they can't provide sufficient collateral.
这就好比,为了维持你的生活方式,你需要拥有相当于你总资产100美元的金额。
It would be as if you, in order to support your lifestyle, needed to have $100 relative to the amount of wealth that you have.
你觉得以你的资产规模,要维持这笔100美元的贷款并借足够资金支付持续利息,会很难吗?
Do you think it would be hard for you to maintain a loan on that $100 based on the amount of assets that you have and borrow enough to pay the ongoing interest?
我觉得这不会很难。
I don't think it would be hard.
但我认为你在这里想表达的是,消费并不会随着财富成比例增长。
But something I think you're getting at here is consumption doesn't scale.
所以我们讨论的是他们如何为奢华的生活方式提供资金。
So even we're talking about how do they fund their lavish lifestyles look.
我不知道埃隆·马斯克每年的维持成本是多少。
I don't know what Elon Musk's carrying cost is year on year.
我不知道他有多少套房子之类的。
I don't know how many homes he's got or whatever.
但假设他的开销在两千五百万到一亿美元之间。
But say it's between 25,000,000 and a $100,000,000.
是的。
Yeah.
这不过是零花钱而已。
It's penny change.
没错。
Yes.
正是如此。
That's exactly it.
另一点是,如果他们出售股票,就会面临失去对公司控制权的风险,同时也可能无法享受到股票未来的增值。
And the other thing is is that if they sell the stock, they run the risk of giving up control over their companies, and they also run the risk of not being able to enjoy the future growth of their stock.
这些公司都在飞速发展,他们不想放弃任何股权。
These are companies all heading into the stratosphere, and they don't wanna give up any ownership.
他们想继续搭乘这趟列车,而他们的股票已被证明是非常好的选择,因为价值增长远远超过了他们需要支付的利息。
They wanna keep going with this ride, and their stocks have proven to be a very good choice because the growth in value has far outpaced anything they have to pay in interest.
因此,他们能够保留对公司的控制权。
So they get to retain control of their companies.
他们能够享受这些极其盈利的公司价值的上涨,而且这一切都是完全免税的,而我们其他人却只能无奈地承担后果。
They get to ride up the value of these tremendously profitable companies, and they get to do it all entirely tax free while all the rest of us are left, you know, holding the bag.
好吧。
Alright.
所以你讲的这个故事是这样的情况:如果你拥有足够的财富,而美国政府并不将这笔财富视为收入,你就可以以这些财富为抵押借款,从而获得一种免税的资金来源,你可以不断滚动续借下去。
So the story you're telling here is a situation where if you have enough money and that money is not seen by the US government as income, you can borrow against that wealth, and that creates a tax free form of money that you can use, and you just keep rolling it over and rolling it over and rolling it over.
我对此有几个问题。
I have a couple of questions about this.
但在深入这些问题之前,我想把这个情况和第九十九百分位的人做个比较。
But before we get into those, I want to compare this maybe to somebody in the ninety ninth percentile.
假设你是一位比佛利山庄的外科医生,嗯。
Let's say you're a Beverly Hills surgeon Mhmm.
年收入200万美元。
Making $2,000,000 a year.
是的。
Yeah.
再假设你是一位科技创始人,拥有1.8亿美元的公司股票,但年薪只拿一美元。
And then let's say you're a tech founder who has a $180,000,000
嗯。
Mhmm.
公司股票价值1.8亿美元,却只拿一美元年薪。
In company stock and only takes a dollar a year in compensation.
是的
Yeah.
这两个人都很富有。
Both of those people are rich.
没错。
Yep.
他们在纳税方式上有什么不同?
What is the difference in the way they are taxed?
区别就在于,这正是一个完美的例子。
So the difference is is that and that's a perfect example.
比佛利山庄的外科医生将支付大量税款,可能超过其全部收入的50%。
The Beverly Hills surgeon is going to pay a lot of taxes, probably in excess of 50% on all of their earnings.
因此,无论他们一生中积累了多少财富,这些收入在获取时都已经缴纳了可观的税款。
So when they have however much they've accumulated over their lives, they've already paid significant taxes on that acquisition of revenue.
然而,我们的科技人士虽然只有1.8亿美元——不是亿万富翁,只是个小角色——却完全免税地实现了这笔财富。
However, our tech person who has a mere a $180,000,000, right, not a billionaire, a piker, Still has achieved this $180,000,000 entirely tax free.
除非他或她出售股票,否则无需缴税。
There is no tax unless he or she sells the stock.
由于他们没有必要出售股票,也不愿意出售股票,因此他们通常不会出售。
And because they don't have to sell the stock, because they don't want to sell the stock, They often don't sell the stock.
在美国,他们永远不需要为这笔收益缴税。
And here in The United States, they never have to pay taxes on that gain.
那么,当他们将股票传承下去时,会发生什么?
And so then what happens when they pass that stock down?
我们没有人能永生,尽管有些人确实在努力尝试——考虑到我们在这里谈论的财富水平。
None of us live forever, even though some of us are definitely trying, predicting the levels of wealth we're talking about here.
但假设他们没有解决这个问题,是的。
But assuming they don't figure that out Yeah.
当今的巨富去世时
When the very rich today pass away
嗯。
Mhmm.
这些股票或其他我们可能想到的资产在传承时,从税收体系的角度来看会发生什么?
And this stock or these other forms of assets we might be thinking about get passed down, what what happens from the perspective of the tax system?
没错。
Right.
所以,理论上,遗产税本应在此时生效。
So, theoretically, what's supposed to happen is that the estate tax is supposed to kick in.
它的目的是通过对赠与和死亡传承征税来应对这些转移,税率相当高,超过免征额部分。
And its purpose was to address these transfers by gift and at death by imposing a tax at a pretty significant rate in excess of an exemption amount.
如今,这一税率在超过1500万美元的部分为40%,因此,理论上,我们的两位纳税人如果需要就超过1500万美元的财产转移缴纳40%的税,都将面临相当沉重的税负。
Today, that rate is 40% in excess of $15,000,000 So, theoretically, both of our taxpayers are going to be subject to some pretty significant tax liability if they have to pay a 40% tax on the transfer of property that's over $15,000,000.
这就是我们设想的系统运作方式。
That's how we imagine the system working.
但问题是,遗产税已被各种漏洞侵蚀得面目全非,实际上已名存实亡,几乎不再构成真正负担。
The problem is that the estate tax has become so riddled with loopholes that it is really more of a tax in name only than it is an actual burden.
我可以给你我认为最能说明这一点的证据:废除死亡税是共和党人最重要的议题
And I will give you what I think of as the ultimate evidence of this, which is that killing the death tax was the number one issue for the Republicans for
这就是他们所称的。
Which is what they called.
这就是他们所说的遗产税。
Which is what they called the estate tax.
取消遗产税或废除死亡税是共和党人过去至少三十年的主要议题。
Getting rid of the estate tax or killing the death tax was a big issue for the Republicans for at least the past thirty years.
然而,在2025年,当他们有机会这样做时,我们有了特朗普总统。
However, in 2025, when they had the chance to do it, we had president Trump.
我们有一份完全由共和党主导的税法法案,他可以加入任何他想要的内容。
We had an entirely Republican tax bill, and he could include anything he wanted.
突然之间,遗产税废除条款却不见了。
All of a sudden, estate tax repeal wasn't there.
这是为什么呢?
And why is that?
我认为这是因为遗产税已经漏洞百出,对富人而言,保留遗产税反而更有利——它制造出富人正在缴税的假象,而如果真的废除遗产税,反而会暴露所得税体系如何让继承财富受益。
I think it's because the estate tax has become so riddled with loopholes that it serves the wealthy more to keep the estate tax on the books, giving the appearance that the wealthy are paying taxes than to actually repeal the estate tax, which would shine a light on all of the ways the income tax system benefits inherited wealth.
你的专长是各州。
Your specialty is states.
是的。
Yes.
给我讲讲一些漏洞吧。
Tell me about some of the loopholes.
如果我来找你,是的。
If I if I came to you Yeah.
如果我选择了更有利可图的职业,并且取得了很好的成就,然后我来对你说,嘿。
And if I were had chosen a more lucrative profession and done done done well in it, and I come and say, hey.
我有五千万美元。
I got $50,000,000.
是的。
Yeah.
我想把这笔钱传给我的孩子,不希望政府拿走一分钱。
And I wanna pass that on to my kids, and I don't want the government getting a dime of it.
他们没有赚到这笔钱,也不配拥有它
They didn't earn it, and they don't deserve
是的
it.
对
Yeah.
在你更愤世嫉俗、更功利的版本中,你会怎么做?
What would you in a maybe a more cynical and mercenary version of you Yes.
就像这个更富有、更功利的我
Like the richer and more mercenary version of me here
聚在一起
Getting together.
你会建议我怎么做?
What what would you tell me to do?
对
Yeah.
首先,关键在于你是那位外科医生,还是拥有股票的技术创业者。
Well, first of all, it would matter here whether you were the surgeon or the tech entrepreneur with the stock.
对吧?
Right?
外科医生要困难得多,因为外科医生拿到的是现金。
The surgeon has a much harder time because the surgeon has cash.
他们领的是现金报酬。
They were paid in cash.
他们手上有现金。
They have cash.
而且数额很大
And it's a lot
买了很多股票。
of bought stocks.
他们持有指数基金之类的资产。
They're holding index funds, whatever it might be.
是的。
Yes.
但他们的大部分财富是通过现金积累的,而不是通过未纳税的增值实现的。
But most of their wealth was achieved in cash rather than in untaxed appreciation.
因此,这里正是那些拥有资产(通常是股票)的人能够以他人难以企及的方式利用系统的地方。
And so here is where people who own stuff, typically stock, really are able to take advantage of the system in a way that others can't quite as well.
如果你有一家价值一亿美元的企业,并在你去世时以一亿美元的价格传承,它的估值就是一亿美元。
If you have a business that's worth, let's say, a $100,000,000 and you pass it at death at a $100,000,000, it's valued at a $100,000,000.
然而,如果你把它分割成三份少数股权,比如35%、35%和30%,每一份都可以享有高达40%的折价。
However, if you cut it up into three minority pieces, 35%, 35%, and 30%, each of those pieces is entitled to a discount of up to like 40%.
于是,原本一亿美元的价值突然被压缩到了五千万到六千万之间,然后在下一代手中又重新回升到一亿美元。
Now all of a sudden, $100,000,000 has been shrunk to $50,000,000, $60,000,000, and then it appears on the other side at your kids blowing back up to a $100,000,000.
这就是我们所说的少数股权折价。
That's one way we call those minority discounts.
但更厉害的手段是有人设立代际信托。
But even better are devices where somebody creates a dynasty trust.
这些真的是
These are really the
听起来不错。
Sounds good.
我想设立一个世代信托。
I want a dynasty trust.
世代信托之所以引人注目,是因为遗产税的初衷正是为了避免家族财富的世袭。
And dynasty trusts are fascinating because the purpose of the estate tax was to avoid dynastic wealth.
遗产规划如此明目张胆,以至于人们干脆直接称它们为世代信托,这真是一个信号。
And it's a sign of how flagrant the estate planning can be that they actually just call these dynasty trusts.
是的。
Yeah.
我们知道本不该有世袭家族,但我们偏偏为你造出了世袭家族。
We know they're supposed to not have dynasties, but we got dynasties for you.
它们的作用是建立一种机制,让你的子女、孙子女、曾孙子女、玄孙子女乃至更久远的后代,能够永久受益于这个信托及其不断增值的资产。
And what they do is they create a vehicle for your children, grandchildren, great grandchildren, great great grandchildren forever in perpetuity to benefit from this trust and the growing value of this trust.
它们通过许多复杂的安排获得资金,通常通过销售实现。
And they get funded through a lot of complex arrangements, oftentimes through sales.
你早期会将股票出售给这家公司,换取一张低息票据。
You will sell your stock early on to this company in exchange for a low interest note.
就遗产税而言,你已经将资产移出了你的遗产。
For estate tax purposes, you've gotten it out of your estate.
但就所得税而言,你被视为与自己进行交易,因此这笔转让无需缴税。
But for income tax purpose, you're treated just as if you're dealing with yourself, so you pay no taxes on that transfer.
这些永续信托通过此类手段,正被注入数十亿、数百亿甚至更多的资金。
And these dynasty trusts, through devices like that, are being stuffed with billions and billions and billions of dollars.
这种现象在全国各地都在发生。
And this is happening all around the country.
在全国各地,遗产规划师都在帮助客户为这些永续信托注资。
Around the country, estate planners are helping their clients fund these dynasty trusts.
还有一种慈善工具被使用,大致是你先向慈善机构提供一笔初始权益,然后在最后将资产转给私人,但你通过定价方式,使所有收益在过程中被隐去,直到故事结尾才神奇地显现出来。
There's also charitable vehicles that are used where basically you give a charity an interest upfront, and then at the end, it goes to a private person, but you price it such that all of the gain is somehow written out of the picture until it magically appears at the end of the story.
GRATs和滚动GRATs也是同样的情况。
It's the same thing with GRATs, Rollin GRATs.
GRAT是一种赠与人保留年金信托,它是一种工具,人们通过所谓的‘滚动GRAT’方式,能够免税转移巨额财富。
A GRAT is something that is a grantor retained annuity trust, and, it is a device by which people are able to transfer enormous amounts of wealth tax free by doing something called rolling grats.
资金进来,利润被抽走。
The money comes in, the profits get siphoned off.
资金进来,利润被抽走。
The money comes in, the profits get siphoned off.
所有的利润都完全免税地被抽走了。
And all the profits get siphoned off entirely tax free.
这些只是众多被使用已久的遗产规划工具中的一小部分。
These are just some of the many devices that are used and that estate planners have and have had for too long now.
为什么他们有这么多工具?
Why do they have all these devices?
这些工具是设计来这样使用的吗?
Were they created to be used this way?
它们是为其他目的而设计的,只是人们后来发现了这种用法吗?
Were they created for another purpose and people just figured it out?
是的。
Yeah.
比如,这个税法原本就是设计成这样的,还是被各种精妙的税务操作逐步肢解成这样的?
Like, is this tax code designed to do this, or has it been chopped up through kind of brilliant tax machinations?
让我稍微退一步说。
So let me step back for a second.
为了使税收体系有效运行,纳税人和国会或国税局——无论哪个是监管机构——之间必须有一种互动。
In order for a tax system to work, there has to be a dance between taxpayers and congress or the IRS, whoever is the regulating authority.
基本上,国会制定了一些规则。
Basically, congress sets out some rules.
国税局制定了若干法规。
The IRS sets out some regulations.
纳税人及其遗产规划师或其他顾问会找到绕过这些规则的方法。
Taxpayers and their estate planners or other advisers find ways around the rules.
国会或国税局本应介入并关闭这些漏洞,作出回应,而纳税人则继续寻找其他漏洞,两者之间就这样形成了一种互动,这种机制在很大程度上确保了税收系统能够有效征收国家运行所需的收入。
Congress or the IRS is supposed to come back in here and close the loopholes, respond to that, taxpayers go out, they try to find other loopholes, and together, there's this dance that it does a pretty good job of making sure that the tax system is doing a pretty good job of collecting the revenue we need in the country to run the country.
明白吗?
Okay?
在二十世纪的大部分时间里,遗产税的运作效果相当不错。
For much of the twentieth century, this worked pretty well with the estate tax.
遗产税被视为一种非常无害的税种,在国内广受接受。
The estate tax was seen as a, you know, a very innocuous tax, well accepted in the country.
它作为收入税体系的补充,填补了财富以免税方式增长的各种漏洞。
It serves as a backstop to the income tax system, had all these ways for wealth to grow tax free.
对吧?
Right?
遗产税的存在就是为了兜底,确保这些财富最终要缴税。
And the estate tax was there as like a sweep up tax to make sure that it was gonna be subject to tax.
但问题是,1990年时,这种做法停止了。
The problem was, in 1990, they stopped.
那是我们最后一次对遗产税进行改革。
And that was the last time we have had any reform done to the estate tax.
但遗产规划师们并没有停止。
But, of course, the estate planners haven't stopped.
他们真的停止了吗?
They have Did it stop?
因为据我了解,自那以后我们已经多次削减了遗产税。
Because my understanding is we've had cuts to it since then.
我的意思是,小布什。
I mean, W.
你可以称之为改革,也可以不称之为改革,但遗产税确实被一再削减、分割,变得越来越弱。
Bush, you could call it reform or not reform, but it has been chopped up and sliced up and made weaker.
没错,全部都是。
All that right.
自那以后发生了什么?
What is since then?
好吧,发生的情况是出现了两次变化。
Well, what has happened is that there have been two changes.
免税额度提高了,税率也降低了。
The exemption amount has increased, and the rates have decreased.
因此,围绕这个问题有很多讨论。
And so there is a big discourse around this.
我对此有点印象。
I I remember this a bit.
好像这些人是在传承家庭农场,而他们的家庭农场却被征税掏空了。
It's like, oh, these people are passing down family farms, and their family farms are getting taxed away.
是的。
Yes.
所以他们当时就把税给削减了。
So they they cut it up then.
那么它到底是怎么变化的呢?
So so how does it change?
对。
Right.
所以那种伤害家庭农场和企业的双重征税,也就是遗产税,这个运动在20世纪90年代初是由全国18个最富有的家族资助的。
So that double tax that hurts family farms and businesses, the death tax, that campaign was funded by 18 of the country's wealthiest families in the early nineteen nineties.
比如玛氏、可口可乐、沃尔顿家族,他们都聚在一起,说:好吧。
So the Mars, the Cokes, the Waltons, they all got together, and they were like, okay.
我们已经解决了所得税的问题。
We we got the income tax handled.
对吧?
Right?
我们可以借款。
We can borrow.
我们可以规避工资税。
We can avoid salaries.
但遗产税,国会一直在调整它。
But this estate tax, congress keeps fixing it.
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他们一直保留着隔代转移税。
They keep doing the generation skipping transfer tax.
他们实施了特殊估值规则。
They do the special valuation rules.
我们必须阻止他们。
We gotta stop them.
他们资助了这场运动,以让公众反对遗产税。
And they funded this campaign to turn the public against the estate tax.
他们通过向公众宣传遗产税是一种不道德的死亡税,让人觉得它针对所有人,而不是实际上主要针对富人的遗产税。
And they did so by telling the public that the estate tax was an immoral death tax, making it seem like it came for everyone, right, rather than the estate tax, which definitely had a sort of a a rich people air to it.
所以我只是说,不行。
So I just said, no.
不行。
No.
这是一项死亡税。
This is a death tax.
它影响所有人,尤其对家庭农场和企业造成伤害。
It comes for all, and it particularly harms family farms and businesses.
但他们没有说的是,税法中实际上有许多专门设计来保护家庭农场和企业的条款。
Now what they didn't say was that there are actually a lot of provisions in the tax code specifically designed to protect family farms and businesses.
事实上,国会很难找到真正因遗产税而失去农场的例子。
And indeed, congress had a very hard time finding actual examples of people who actually lost their farms.
他们最常引用的一个人名叫切斯特·菲格彭,他有个农场。
Their favorite person who they used was this fellow by the name of Chester Figpen who had a farm.
这名字真有意思。
What a name.
是的。
Yes.
他是奴隶的孙子,曾在国会作证,说他担心自己死后因遗产税而失去农场。
And he was the grandchild of slaves, and he testified in congress that he was afraid he was going to lose his farm due to the death taxes that were gonna be imposed when he died.
他如此有说服力,以至于共和党人想把这项法案命名为‘切斯特·蒂格彭遗产税废除法案’,因为他是个极具感染力的人物。
He was so effective that Republicans wanted to call it the Chester Thigpen Estate Tax Repeal Act because he was such a compelling figure.
几年后,切斯特·蒂格彭去世了,结果发现他根本不需要缴纳遗产税,因为他的农场远低于免税额度,而且还有其他保护措施。
Well, a few years later, Chester Thigpen dies, and turns out he wasn't subject to the estate tax at all because in fact his farm fell well within the exemption and there were other areas to protect it.
因此,如果真把家庭农场和企业的问题当回事,国会完全可以轻松解决,只需扩大现有的保护措施即可。
So, easily Congress could have easily addressed the family farms and business problem if one sees that as a problem by basically expanding the protections that were already there.
但事实上,他们却利用这个借口,为所有那些拥有巨额继承财富的人——比如马尔斯家族、沃尔顿家族——开脱,让他们能够免税传承财富。
But instead, they were using it as a cover for all of the people, the Mars, the Waltons, all of those people that had massive amounts of inherited wealth, and they wanted to be able to pass it tax free.
明白了。
Okay.
我在你的书里看到这些数字,觉得相当震惊。
So I found these numbers in your book kinda shocking.
2000年,在布什减税之前,美国人提交了12.2万份遗产税申报表。
In 2000, before the Bush tax cuts, Americans filed a 122,000 estate tax returns.
到2010年,这个数字降到了4.7万份。
In 2010, it was 47,000.
2013年,奥巴马的税改方案生效后,进一步降至32,300份。
In 2013, after Obama's tax plan went into effect, it was 32,300.
然后在特朗普之后,2021年只有6,158份遗产税申报表,其中仅有2,584份实际需要缴税。
Then after Trump, there were 6,158 in 2021, of which only 2,584 were actually taxable.
所以,要么从2000年到2021年,富人不死了,要么他们不再富了,要么我们真的把这项税制几乎彻底废除了。
So either between 2000 and 2021, rich people stopped dying, or they stopped being rich people, or we really gutted this thing within an inch of its life.
是的。
Yeah.
我选第三种。
I'm going with number three.
所以到2024年,美国最富有的1%人群控制了该国巨额财富,达50万亿美元。
So in 2024, the richest 1% of Americans controlled massive amounts of the country's wealth, $50,000,000,000,000.
然而,遗产税本应适用于所有死亡时的财产转移和赠与,而赠与行为其实非常普遍,正如我提到的,这些手段都涉及大量赠与。
And yet the estate tax that was designed to apply to all transfers at death and by gift and there's a lot of gifting that goes on because, as I mentioned, those techniques all involve gifting.
因此,这些人进行了大量的赠与行为。
So lots and lots of gifting is going on by these people.
2024年,40%的遗产税仅从美国最富有的1%人群所拥有的50万亿美元财富中筹集了300亿美元。
The 40% estate tax only raised $30,000,000,000 in 2024 out of $50,000,000,000,000 wealth owned by the richest 1% of Americans.
这几乎是微不足道的。
It is practically nothing.
这个数额是埃隆·马斯克一天内赚了又亏掉的,而且他可能根本没注意到。
It is an amount that Elon Musk has both earned and lost in just a single day and probably hardly even noticed.
所以,显然遗产税并没有发挥我们以为它该有的作用。
So, clearly, the estate tax is not doing what we think it's doing.
嘿。
Hey.
我是乔尔。
I'm Joel.
我是来自《纽约时报》游戏的朱丽叶。
And I'm Juliet from New York Times games.
我们在这里和人们聊聊游戏。
And we're out here talking to people about games.
你玩《纽约时报》的游戏。
You play New York Times games.
是的。
Yes.
每天。
Every day.
你有最喜欢的吗?
Do you have a favorite?
Connections。
Connections.
它只是让你思考。
It just makes you think.
我觉得它给了我弹性。
I feel like it gives me elasticity.
把四个四人组分出来。
Create four groups of four.
这其实是个挺棒的游戏。
This is actually a pretty cool game.
你最喜欢的游戏是什么?
What's your favorite game?
填字游戏。
The crossword.
填字游戏?
The crossword?
我和我哥哥一起玩。
I do it with my brother.
我们有时候会做周四的,但我不确定。
We get Thursday sometimes, but I don't know.
我自己就能做周四的。
I can do Thursday on my own.
我觉得我在学习。
I feel like I'm learning.
我觉得我在完成一些事情。
I feel like I'm accomplishing something.
我喜欢完成的时候。
I like the when you finish it.
我家人玩Wordle,我们有个很大的群聊。
My family does Wordle, we have a huge group chat.
比如,我奶奶玩Wordle。
Like, my grandma does Wordle.
你奶奶玩Wordle。
Your grandma does Wordle.
哦,每天都玩。
Oh, every day.
是的。
Yeah.
你对Wordle有什么强烈看法吗?
Do you have a Wordle hot take?
你应该从一个策略上很糟糕的词开始,这样会更有趣。
You should start with a word that's strategically bad to make it more fun.
所有的
All of
这些游戏都很有趣,因为它们就像五到十分钟的小休息。
these games are so fun because it's like a little five to ten minute, like, break.
我爱这些游戏。
I love these games.
是的。
Yeah.
纽约时报游戏订阅用户可以完全访问我们所有的游戏和功能。
New York Times game subscribers get full access to all our games and features.
现在访问 nytimes.com/games 订阅,享受特别优惠。
Subscribe now at nytimes.com/games for a special offer.
这听起来可能很傻,但我认为值得聊一聊。
This will sound stupid, but I think it's worth talking about.
为什么会有不同的速率呢?是的。
Why are there different rates Yeah.
针对不同类型的收入吗?
For different kinds of income?
为什么我们对待在工作中赚取的收入、出售股票所得的收入、以及有人去世后留给我们的遗产或他人赠予的收入,都区别对待呢?
Why do we treat income earned at our job, income earned by selling stock, and, you know, income earned when somebody dies and, you know, leaves everything to us or income given to us as a gift?
为什么我们要对它们区别对待?
Why do we treat them all differently?
我们理论上究竟想实现什么?
What what what are we trying in theory Right.
实现什么?
To achieve?
安德鲁·梅隆,这位以激烈反税著称的人物,认为
Andrew Mellon, who is was known as a tremendous anti tax crusader, felt that
该死的强盗资本家。
Damed robber baron.
是的。
Yes.
同时,作为多位政府内阁的财政部长,他认为规则应该是:劳动收入适用最低税率,而投资收入适用最高税率。
And also, secretary of the treasury and for a number of administrations, felt that the rules should be that income is taxed at the lowest rates, and investments are taxed at the highest rates.
因为赚取工资收入的人处境最为脆弱,他们更需要较低的税率,而那些仅仅依靠投资收益的人则不然。
Because people earning income, they are in the most precarious situation, and they are likely to need the lower rates as opposed to people who are just sitting back and relying on their investments.
让让
Let let
让我念一下这里的引文。
me read the quote here.
我记下了这段话。
I I took this down.
这出自你的书。
It's in your book.
这是来自安德鲁·梅隆1924年所著的《税收:人民的事务》。
This is from Andrew Mellon's 1924 book, taxation, the people's business.
他写道:对工资、薪金或投资收入实行较轻的征税,其公平性是毋庸置疑的。
He writes, the fairness of taxing more lightly income from wages, salaries, or from investments is beyond question.
在第一种情况下,收入是不确定且短暂的。
In the first case, the income is uncertain and limited in duration.
疾病或死亡会使其消失,年老则会削弱它。
Sickness or death destroys it, and old age diminishes it.
这里,他谈论的是工资。
Here, he's talking about wages.
在另一种情况下,收入的来源是持续的。
In the other, the source of income continues.
一个人在世时可以处置其收入,它也会传给他的继承人。
The income may be disposed of during a man's life, and it descends to his heirs.
安德鲁·梅隆的意思是,对工资收入征收较轻的税,而对投资收入征收较重的税,这一点毫无疑问。
That Andrew Mellon was saying that it was beyond question that you should tax wage income more lightly than investment income.
我的意思是,这反映了一个完全不同的时代。
I mean, it speaks to a very different time.
那么,是什么样的思维方式让我们进入了如今这个局面——无论你怎么看待税法,结果都是相反的:收入越高,税率越低?
So what is the thinking that leads us into the the current world where no matter how you think about the code, it is the reverse income.
你知道吗,如果我卖出股票,所得会被征较轻的税,是的。
You know, if I sell stock, that gets taxed more lightly Yeah.
相比我在《纽约时报》工作所得的收入,股票收益的税率更低。
The income from that than the income I make from The New York Times.
是的。
Yeah.
有趣的是,当你深入研究时,会发现有五十种理由被用来论证为什么资本收益应该适用更低的税率。
And what's interesting is when you actually dive into it, there are 50 reasons of arguments that are given about why investment gains should be taxed at a lower rate.
比如,如果时间跨度很长,可能会有大量通胀,所以这些收益可能并非实际增长。
Things like there might be a lot of inflation if a lot of time has passed, so maybe it's not actual gains.
有些人说,降低税率有助于鼓励投资。
And some say it's good to encourage investments.
还有人说——我觉得这是最扭曲的逻辑——他们认为,现在人们因为不卖出股票就能避税,所以被鼓励长期持有。
And others say, and I find this the ultimate in distorted reasoning, they say, look, Right now, people are encouraged not to sell their stock because they can avoid tax by not selling.
我们必须降低税率,才能诱使他们卖出股票。
We have to lower the rates in order to lure them into selling.
因此,这是另一个理由,尽管他们应该直接对收益征税,那样人们就会出售了。
And so that is another justification even though they should just tax the gains, and then people would sell.
我认为他在这里使用的词‘公平’也很有意思。
It's also the word he uses here, I think, is interesting, fairness.
我参与这个辩论已经很久了。
I've been around this debate a long time.
我曾报道过
I've covered a
很多关于税收的辩论。
lot of tax debates.
我曾报道过关于资本利得税率的辩论。
I've covered debates on the capital gains tax rate.
深入过很多关于效率的争论,以及究竟在宏观层面把旋钮调到哪个位置才最恰当。
Get into a lot of arguments about efficiency and, you know, the the exactly right macroeconomic level to turn the dial to.
但作为一个普通人,真正体验过收入是如何运作的,我为自己的劳动所得付出了那么多努力。
And yet, as a human being, right, just experiencing the way income works, I work so hard for the income I make from my work.
我的意思是,你是个送货司机。
I mean, you're a delivery driver.
你是一名从事全科医疗工作的医生,或者是一名儿科医生,你工作得如此辛苦。
You're, you know, a doctor doing primary care work or a pediatrician, you're working so hard.
而竟然有人仅仅把钱放在指数基金里,就能享受低得多的税率,这太不公平了。
And the idea that that is taxed so much more higher than somebody making money by just letting money sit in an index fund.
对吧。
Right.
或者偶尔点一下按钮,把资金在不同的投资之间转移。
Or just occasionally clicking a button and move it between Right.
你知道的,不同的投资方式。
You know, different investments.
这里确实存在一个公平性问题。
There is a fairness question here.
这太残忍了。
It it's cruel.
我一直觉得这实际上相当残酷。
I always think it's, like, actually quite cruel.
让你的钱为你赚钱实在太容易了。
It is so easy to let your money make money for you.
我们竟然奖励这种行为,而不是奖励劳动,这在我看来太疯狂了。
The fact that we reward it over work is crazy to me.
我完全同意。
I totally agree.
你知道还有谁也同意吗?
And you know who else agreed?
里根在1986年的税改法案中就同意过。
Ronald Reagan in the '86 tax act.
他们确实曾短暂地实现了资本利得税率与普通收入税率的平等。
They actually succeeded in equalizing for a very brief period capital gains rates and ordinary income rates.
他们取消了对资本利得的优待,而我们今天绝对应该这么做。
They got rid of the preference for capital gains, which we should definitely do today.
现在,如果我们要讨论的话,有人可能会提出一个论点:是的,但当富人把他们的钱投资到经济中时,每个人都会从中受益。
Now one of the arguments that someone's gonna make if we're you know, is yes, but everybody is better off when rich people take their money and they invest in the economy.
这正是推动整个国家增长的原因。
That's what makes the whole country grow.
但问题是,这些资金很多并不是用于支持本地企业起步的种子资本。
But the thing is, much of this money is this is not seed capital to start local businesses.
这些钱是在二级股票市场上进行交易的。
This is money trading on a secondary stock market.
它们并没有流向任何企业。
It is not going to a business.
而是流向了其他股票持有者,推高了股价。
It's going to other owners of stocks driving up the shares.
因此,我不认同这种说法,即人们把钱投入股市就是在推动经济增长。
So I don't buy that argument that this is growing the economy when people are putting their money in stocks.
那让我问问与此相关的一个方面,那就是股票回购的兴起。
Well, let me ask about a related dimension of this, which is the rise of stock buybacks.
是的
Yeah.
还有股票运作方式的变化,嗯。
And both how that has changed the way stocks work Mhmm.
以及应税收入如何呈现或不呈现,是的。
And how that has changed the way taxable income Yeah.
表现出来或不表现出来。
Presents or does not present itself.
我们一直讲述一个关于富人不为其股票缴税的故事,因为他们的股票价值上涨。
We've been telling a story about wealthy people not paying taxes on their stock because their stock goes up in value.
他们不需要为这种收益缴税。
They don't have to pay tax on that gain.
然而,在1982年之前,由于公司只能通过股息分配利润,拥有大量股票意味着获得大量股息。
However, prior to 1982, because companies could only share their profits through dividends, what it meant to own a lot of stock was to get a lot of dividends.
在20世纪的大部分时间里,股息像工资一样按最高税率征税。
And for much of the twentieth century, dividends were taxed at the highest rates, just like salaries.
因此,这意味着持有大量股票的人会获得大量股息,并缴纳大量税款。
And so what that meant was that somebody who was sitting on a lot of stocks got a lot of dividends and paid a lot of taxes.
然而,1982年这项规则变更后,公司开始停止发放股息。
However, in 1982, after this rule change, companies switched from issuing dividends.
过去,超过70%的利润是通过股息分配的。
It used to be more than 70% of profits were distributed through dividends.
自这项变更实施以来,股息比例从未再超过20%。
Now it has never been as high as 20% since this change went into being.
其影响是,公司开始大量回购自己的股票。
The effect of it is that companies began to do lots and lots of buybacks of their stock.
这在多个层面上产生了巨大影响。
And this had a tremendous impact on multiple levels.
一是如果你看道琼斯指数,我书中有一张图表显示,1982年道琼斯指数约为3000点。
One is if you look at the Dow Jones, there's a chart in my book that shows that 1982, the Dow Jones was at about 3,000.
同时,在七十年代、六十年代、五十年代、四十年代、三十年代和二十年代也是如此。
It was also that in the seventies, the sixties, the fifties, the forties, the thirties, and the twenties.
当时大约是3000点。
It was around 3,000.
这是经过通货膨胀调整后的金额。
It's inflation adjusted amount.
现在则达到了四万五千左右,大概是这样。
Now it's like in the forty five thousand, something like that today.
对吧?
Right?
这个故事的一部分是股票回购,因为股票回购会推高股价。
And part of this story is stock buybacks because stock buybacks boost the value of stock.
但这个故事的另一个重要部分是,对于持股者来说,他们不再需要缴纳所得税,因为他们可以通过股价上涨来实现收益。
But another important part of the story is that it meant that for somebody who owned stock, they no longer had to get taxable income because they could enjoy their profits through the increased value of the stock.
一些股东会卖出他们的股票,因为这就是股票回购的性质。
Some shareholders would sell their stock because that's the nature of the stock buyback.
然而,许多这些股东是免税机构,因此他们并不担心为收益缴税。
However, a lot of these shareholders are tax exempt organizations, so they are not worrying about paying taxes on their proceeds.
因此,从联邦政府的收入角度来看,盈利公司过去通过股息征税为政府提供了大量收入。
So in terms of revenue to the federal government, profitable companies used to provide a lot of revenue to the federal government in the form of taxation of dividends.
而随着股票回购的兴起,这种情况现在不太可能再发生了。
And now with the rise of stock buybacks, that is much less likely to be the case.
所以我想回到这个问题:当这些巨额财富传承下去时,会发生什么?
So then I wanna go back to the question of what happens to these great fortunes when they get passed down.
从税收角度来看,你是如何看待这种情况的?
How is that treated for you from a taxation perspective?
比如,什么时候会
Like, when when does that
征税?
get taxed?
对。
Right.
所以,如果你在去世时继承了财产,那么对于继承增值财产的人来说,会有一个额外的优惠。
So if you receive it at death, then there is an extra benefit for people who receive appreciated property at death.
而且,这不仅意味着持有股票的人无需为这些收益缴税,当有人通过继承获得股票时,所有这些收益都会被清零。
And that is that not only are those gains not taxed to the person who held the stock, But when somebody receives the stock from inheritance, all the gains are wiped away.
我们称之为成本基础上调,或者
We call this step up in basis or
一个挺神秘的好名字。
the A nice inscrutable name.
是的。
Yes.
或者叫‘死亡天使漏洞’。
Or the angel of death loophole.
这个叫法更好。
That's better.
是的。
Yes.
而‘死亡天使漏洞’意味着我们会抹去这些收益,继承人将被视为自己购买了这项财产。
And, and the angel of death loophole says that we're gonna wash away the gains, and the recipient is gonna be treated as if they had purchased the property.
好的。
Okay.
我想放慢一点,因为我觉得这里的成本基础上调非常重要。
I wanna slow this down for a because I think step up basis here is really, really quite important.
假设有人做了一个非常成功的投资。
Let's say somebody made just great investment.
他们在NVIDIA还便宜的时候就买了。
They bought NVIDIA when it was cheap.
几年后,他们持有的股票价值达到了3000万美元。
And, you know, now some years later, they have $30,000,000 worth of it.
在一个情况下,他们卖掉了这些股票,因为他们想买一座豪宅之类的。
In one world, they sell that stock because, you know, they wanna buy a mansion or whatever it might be.
在另一种情况下,他们从未卖出这些股票。
In another world, they never sell the stock.
他们去世后,把这些股票留给了继承人
They pass away and give it
全部留给他们的孩子。
all to their kids.
是的。
Yeah.
这笔股票的税务处理有什么不同?
What is the difference in tax treatment for that stock?
这是同一笔股票。
It is the same tranche of stock.
对。
Yes.
所以在第一种情况下,他们需要就这些资本利得缴纳所得税。
So in the first scenario, they would pay income taxes on this, on the capital gains.
资本利得税率为20%,另外还要加收3.5%的附加税。
The capital gains is imposed at a 20% rate plus an additional three and a half percent extra tax on it.
因此,这些收益中的近四分之一——而这些几乎全是收益——都将被征收所得税。
So almost a quarter of it of those gains, and it's almost all gains, would be subject to income tax.
所以收益是你买入价和卖出价之间的差额。
And so the gains are the difference between what you bought it at and what you sold it at.
没错。
Absolutely.
但如果你持有这支股票不卖,而是去世后传给子女,就会有一个额外的好处。
If instead you hold on to that stock and you don't sell it and you pass it on at death to your kids, there is an extra bonus.
这个好处是,你不仅不用为这笔收益缴税,而且当他们继承财产时,会被视为以公允市场价值购入。
And that is that not only did you not pay taxes on that gain, but when they get the property, they are treated as if they had purchased it for its fair market value.
因此,他们现在被视为以三千万元买入,于是他们可以立即以三千万元卖出,完全不用缴纳任何资本利得税。
And so now they're treated as if they had bought it for $30,000,000, and so they can turn around and sell it for $30,000,000 and pay no gains at all.
这就是我们所说的成本基础上调,或者叫‘死亡天使漏洞’。
And that is this thing that we call step up in basis or the angel of death loophole.
所以这些收益就直接被抹去了?
So the gains are just wiped away?
完全抹去。
Wiped away.
这不用你操心。
Not for you to worry about.
这挺不错的。
That's pretty sweet.
是的。
Yes.
这是一笔非常划算的交易。
It's a very nice deal.
那你觉得杰夫·贝索斯会怎么样?
So what do you expect will happen with a Jeff Bezos then?
他能不承担多少税务影响就把价值一千五百亿美元的资产传给下一代吗?
Can he pass down a 150,000,000,000 or whatever it is without too much tax implication?
或者或者
Or or
他会在意这150亿吗?听起来已经是一大笔钱了。
is he gonna matter about 150 it seems like a lot of money.
这些人很可能会利用慈善工具作为其免税转移的重要手段。
Chances are what these people are gonna use are charitable vehicles as an important part of their tax free transfers.
问题是,这些慈善工具为捐赠者及其家庭带来了巨大的税收优惠,同时继续赋予他们对世界的巨大影响力。
And the problem is that these charitable vehicles afford these donors and their families enormous tax benefits while continuing to give them enormous power in the world.
而一些这类避税工具——它们是在生前设立的——并不仅仅用于慈善,还用于影响政治。
And some of these vehicles, these tax avoidance vehicles, they set them up during life, are not just for charity, but are to influence politics.
这是因为你可以把钱注入501(c)(4)组织,这是一种被允许参与政治活动的特定类型机构。
And that's because you can put money into a five zero one c four, a particular type of organization that is allowed to engage in political activity.
根据我们现行的规定,当你捐赠增值股票时,比如有人决定向他们的(c)(4)组织捐赠500亿美元,他们不仅能继续控制这些资产,还能免税规避赠与税和资本利得税。
And under our current rules, when you give your appreciated stock, let's say somebody decides to give $50,000,000,000 to their c four, they get to have continued control over the assets and a tax free path to avoid both gift taxes and capital gains taxes.
我们来谈谈你可能如何应对这些问题。
Let's talk about what you might do about some of this.
我认为现在人们经常听到的一个话题是财富税。
I think something people are hearing a lot about right now is a wealth tax.
是的。
Mhmm.
他们之所以听到这个提议,是因为今年加州 ballot 上有一项一次性 5% 的财富税。
One reason they're hearing about it is that there is a wealth tax on the ballot in California this year, a one time 5% wealth tax.
州政府和联邦政府在实施这类税制时运作方式略有不同。
These operate a little bit differently for states and and for the federal government.
那我们先从最受关注的加州方案说起。
So let's begin with the the one in the news, which is the California one.
它将如何运作?
How would it work?
你对它怎么看?
What do you think of it?
一个州在考虑推行这种税制时,需要考虑哪些因素?
What are the considerations for a state thinking about doing this?
财富税是解决这个问题的明显方案。
The wealth tax is an obvious answer to this problem.
它表明:我们目前有太多途径让人规避应税收入,而他们却积累了巨额财富。
It says, alright, we have a lot of ways that people are avoiding taxable income, and they have massive amounts of wealth.
让我们对他们的财富征税,实施5%的统一税率。
Let's tax their wealth, and we'll impose a flat tax 5%.
对各州来说,这个问题有几个方面,其中一个问题是人们可以轻易离开该州。
The problem for states is is sort of a few problems, but one of them is that people can easily leave states.
现在加州正试图通过实施这种追溯性的一次性税收来规避人们离开州的问题。
Now California is trying to get around this problem of people leaving the state by making it this sort of retroactive one time tax.
它已经追溯适用于此前居住在该州的人,我认为是从1月1日起生效。
It already applies retroactively to people who previously were living in the state, I think, as of January 1.
追溯性的一次性税收,显然不会是解决这个问题的永久方案。
A retroactive one time tax, I think, is not gonna be a permanent solution to the problem, obviously.
而且我认为它也无法阻止人们离开该州,因为一旦发生过一次,人们自然会预期它还会再次发生。
And nor do I think it's gonna prevent people from leaving the state because once there's a done once, there's every reason to expect it will be done again.
因此,我认为各州在增加财政收入方面确实面临困难,因为其他州正在通过低税率进行竞争。
So I do think there is a problem for states in their ability to raise revenue because other states are trying to compete on these low taxes.
所以在这种情况下,你就会看到佛罗里达州的罗恩·德桑蒂斯这样的情况,没错。
So you have in that case is something like Ron DeSantis in Florida Absolutely.
试图吸引。
Trying to attract.
我不久前认识了一个富人,他给我看了一个应用程序,记录他在佛罗里达州度过的天数,因为他其实很想住在纽约。
I met a rich person not long ago who showed me an app they have that counts the number of days they spend in Florida because they really wanna live in New York.
是的。
Yeah.
对。
Yeah.
但他们住在佛罗里达。
But they live in Florida.
我的意思是,他们确实每年在佛罗里达住够足够的天数,以避免缴纳纽约州的税,我觉得这很疯狂,因为我原以为富有就意味着不必为这种事操心。
I mean, they actually do live in Florida just enough days a year to not pay New York taxes, which I found crazy because I figured the whole point of being rich was to not have to worry about things like this.
你知道,我认为这就是为什么但
You know, I think this is why But
人们真的会这么做,我想。
people really do it, I guess.
是的。
Yes.
我觉得,富有却不得不住在自己不喜欢的地方,这简直太疯狂了。
I think I find it insane to be rich and to have to live somewhere that you don't wanna live.
但当然了,这就是为什么你是播客主持人,而我是法学教授。
But, of course, this is why you're a podcaster, and I'm a law professor.
对吧?
Right?
如果我们真的那么在乎钱,或许也会更在意税收问题。
If we really cared about money, maybe we'd really care about taxes.
因为对我来说,这看起来太荒谬了,但人们却经常这么做。
Because to me, it seems insane, but people do that all the time.
所以你觉得,财富税提案对加州有利,还是只会让德克萨斯州受益,吸引这些富人过去?
So do you think the wealth tax proposal would be good for California, or is it something that would just create a benefit for Texas because it'll pull in these rich people?
嗯,如果这只是一次性税收,很难说它会产生多大影响。
Well, it's hard to say that it's gonna make a huge difference when it's just a one time tax.
所以这必须是一个更持久的税,我认为它存在不少问题。
So it would have to actually be a more permanent tax, and I think it has a number of problems.
其中一个问题是人们会离开。
One of them is the problem of people leaving.
但我认为另一个非常重要的问题是,你如何获取一个人拥有多少财富的信息。
But I think another really significant problem is how you're going to gather the information of how much wealth the person has.
对于拥有上市公司股票的人,我们很容易知道他们持有多少股票,以及他们拥有多少资产。
It's very easy to think about somebody who owns publicly traded stock, and we know how much stock they own, and we know how much they have.
但有很多富人将财富以其他形式持有,而这些形式很难估值。
But there's are lots and lots of wealthy people that own their wealth in other forms that are very difficult to value.
现在你谈的是,州税务部门必须建立资源,让每个人向他们申报所有资产,并持续跟踪这些资产的估值。
And now you're talking about a state department of revenue having to build up the resources to have everybody tell them everything they own and keep up with valuation of it.
这会非常迅速地变得复杂。
It's it's gonna be quite fast.
你的艺术收藏值多少钱?
Your art collection worth?
没错。
Exactly.
你的加密货币NFT值多少钱?
Are your crypto NFTs worth?
当然。
Absolutely.
而且当你开始考虑合伙权益这类事物时,它们是极其复杂的结构,不可能让任何人去监控所有纳税人的这类资产。
And if also, when you start to look at things like partnership interests, these are highly complex structures, and it's impossible for somebody to be able to monitor that for all of the different taxpayers.
所以,要解决这个问题在实际操作中非常困难。
So it's a very, very difficult practical task to get around.
再说一遍,加利福尼亚州有一些解决方案,比如可以延迟缴税等等,但实施起来依然非常困难。
Again, California has some solution where you can defer paying taxes and all of these things, but it's just very difficult to do.
这并不像听起来那么简单。
It's not as easy as it sounds.
而且我认为,这在争取美国公众支持方面也是一个问题,因为我们对房产的价值缴税。
And I think that it's also a problem in terms of winning the support of the American public because we pay taxes on the value of our homes.
但一般来说,当我们考虑所有资产的价值时,我们知道在去世时会有遗产税,但这与要求人们每年披露其一生中拥有的每一件物品截然不同。
But generally, when we think of the value of all of our assets, we know that there's an estate tax at death, but that's very different than requiring people to disclose every single thing they own during their lives every year.
我认为,这会让公众感到侵犯隐私,不仅对那些受规则约束的人如此,对那些思考这些规则公平性的人也是如此。
That, I think, is going to feel invasive to the public, not just to the people who are subject to the rules, but to the other people who are thinking about the fairness of these rules.
但这个问题同样适用于联邦财富税,这或许让我们回到了这一点。
But but that question also applies to a federal wealth tax, which maybe brings us to that.
所以,我认为,这些提案如果非要与某个人联系起来,那很可能就是伊丽莎白·沃伦,她多年来一直提出过多项此类方案。
So, you know, I think to the extent these proposals are associated with anybody, it's probably Elizabeth Warren who has had a number of them over the years.
但也存在各种形式的全国性财富税提案。
But there are proposals for different forms of national wealth tax.
你知道的吗?
You know?
比如,每年按你财富的百分之二征收,年复一年。
Something like it could be two percentage points of your wealth every year, year on year.
你怎么
How do you
想想这个问题?
think about this?
是的。
Yeah.
所以在联邦层面,我认为你可以避免人们迁移的问题。
So in the federal level, you get to avoid the problem, I think, of people moving.
有时候人们会说,哦,不会吧。
Sometimes people say, oh, no.
人们会离开美国。
People are gonna leave The United States.
要摆脱美国的税收管辖是非常困难的。
It's it's very hard to leave the tax clutches of The United States.
而且,现在这个时代,很少有人愿意定期放弃美国公民身份,去成为其他国家的公民。
And, also, this is not an age in which people a lot of people wanna regularly give up their US citizenship and become a citizen in some other country.
比如迪拜之类的。
Dubai or whatever.
没错。
Exactly.
所以人们声称这是
So people claim that's
目前看起来不太好。
looks bad at the moment.
是的。
Yes.
没错。
Exactly.
迪拜移民,英国富人有时会这么做,我认为最近的战争已经让这种做法受到质疑。
Dubai move, which people in The UK the rich in The UK sometimes do and I think has been called into question by the recent, war.
是的。
Yes.
没错。
Exactly.
所以我认为,人们经常威胁说这种情况会发生。
And so I think that's something that people threaten will happen.
我不认为这种情况会在这里发生。
I don't think that would happen here.
但这里更大的问题是宪法问题。
But the bigger problem here is the constitutional issue.
我们的联邦宪法基本上对直接税和间接税有特殊规定,而财富税会引发宪法问题,因为我们宪法对直接税有限制。
So, our federal constitution basically has these special rules about direct taxes and indirect taxes, and wealth taxes raise constitutional issues, it's hard because we have a limitation in our constitution on direct taxes.
问题是,考虑到我们当前的最高法院,我们有充分理由认为,这个最高法院可能会判定财富税违宪,而这种税制很可能无法存活。
And the problem is that given our current Supreme Court, we have every reason to think that this supreme court might find a wealth tax unconstitutional, which it could very easily not survive.
因此,所有这些政治努力都将白费。
So all of that political effort will have been spent for nothing.
而且这似乎并不是一个明智的做法,尤其是在当今世界,富人能够通过各种避税途径轻易避税,而我们却未能对他们的投资收益和遗产征税。
And it just seems like not a smart way to go, particularly in today's world where the wealthy are able to avoid taxes so easily through this sort of highway of alternatives of tax avoidance because of our failure to tax their investment gains and their inheritances.
所以我认为,还有更多更简单的路径可以遵循。
So I think there's there's a lot more easier paths to follow.
它不会像财富税那样立即见效,但更有可能产生持久效果。
It's not gonna be as immediately effective as a wealth tax, but it's more likely to be permanently effective.
那你会怎么做呢?
So then what what would you do?
是的。
Yeah.
所以我认为应该这样做:首先,我们必须关注投资收益。
So what I think should happen is, first of all, we have to look at investment gains.
而我们投资收益的问题在于,除非持有人出售资产,否则永远不会对其征税。
And the problem with our investment gains is that they are never taxed to the person who owns it unless they sell the property.
然而,在加拿大,他们有更广泛的规定。
However, in Canada, they have a much broader rule.
这项规定是:每当个人转让资产时——不仅限于出售,还包括赠与或死亡时——都会计算此时的收益,该人必须就这些收益缴税。
And that rule is that whenever the person transfers the property, not just by sale, but also by gift or at death, the gains at that time will be tallied, and the person will have to pay tax on that gain.
这样,收益就会由获得它们的人缴税,而不是推迟到未来可能永远不会到来的时刻。
And that way, gains are taxed to the person who earned them rather than kicking it down the road to some time in the future that may never come.
如果让我来制定规则,我会说我们应该消除资本利得与普通收入之间的区别,对持有期间的通胀进行调整,除此之外,对这些收益适用普通收入税率。
I if I could write the rules, I would say that we've that we should eliminate the distinction between capital gains and ordinary income and give them an inflation adjustment to reflect that inflation holding, and other than that, impose ordinary income rates on that gain.
此外,我们需要解决继承问题。
In addition, we need to address inheritances.
人们正在以完全免税的方式获得巨额财富。
So people are receiving massive amounts of wealth entirely tax free.
如果你走在街上捡到100美元,你有义务向联邦政府申报。
If you were to walk down the street and find a $100, you would be expected to report that to the federal government.
然而,如果有人送你1000亿美元,你根本不需要向任何人报告。
However, if someone were to give you $100,000,000,000, you literally don't have to tell anyone.
你的报税表上甚至没有一行可以申报,因为这被视为完全是你的私事。
There's not even a line on your tax return to let anyone know because that is seen as entirely your business.
我们不应当让这种情况继续存在。
And we should not have that be the case.
我们应该废除遗产税,因为它根本起不到任何作用。
We should get rid of the estate tax, which isn't doing anything.
确实。
True.
你可以直接把一千亿美元送给人,却不需要向任何人申报吗?
You could just hand somebody a $100,000,000,000, and you don't have to report it to anybody?
送钱的人本应申报赠与税申报表。
The person who hands it is supposed to report a gift tax return.
对吧?
Right?
但如果这笔钱被放入信托,信托增值后从信托中分配出来。
But if it's been put into a trust, the trust has grown, it's distributed from the trust.
接收财产的人可能因复杂的税务规则而产生一些穿透性收益,对吧?
The person receiving the property may have some flow through gains through complicated tax rules, right?
但通过赠与、继承或人寿保险获得财产时。
But the receipt of property by gift, inheritance, or life insurance.
顺便说一句,人寿保险是超级富豪传承财富的首选工具。
And by the way, life insurance is the favorite vehicle of the super wealthy to pass their wealth.
当他们将其转化为人寿保险政策时,突然间所有金额在任何地方都变得免税了。
When they convert it into a life insurance policy, it all of a sudden becomes nontaxable everywhere.
这些属于免税项目,意味着你甚至不需要申报。
Those are subject to exclusions, meaning you don't have to even report them.
你刚才描述的方式让我明白了一点:一方面有税收制度的设计,另一方面则是执行税收设计的意愿,也就是说,如果你设想你所提到的那种改革,你或许能制定出来,但你必须真正希望它生效,从而开始关闭所有这些其他漏洞,并且持续保持关闭状态。
You know, one thing that the way you just described that, I think, makes clear is that there's the level of tax design, and then the there's the level of the will to enforce tax design, which is to say that if you imagine the kind of reform you're talking about, you could make it, but then you would have to actually want it to work, such that you began shutting all this other stuff down and keeping it shut down.
对吧?
Right?
比如你提到的那些人寿保险的漏洞。
Like, life insurance loopholes you're talking about.
但你是如何思考这两个层面的呢?
But how do you think about these two levels?
对吧?
Right?
一方面有税收制度的设计,另一方面则是税法本身非常复杂。
There's a level of tax design and then the level of the tax code is complex.
人们并不了解其中发生了什么。
People don't know what's happening in it.
但那些了解内情的人有非常强烈的动机去支持那些允许他们继续利用这些漏洞的政客,或惩罚那些试图关闭这些漏洞的政客。
And but the people who do know what's happening in it have a very, very, very strong incentive to support politicians who will allow them to keep using these loopholes or to punish politicians who try to close them.
是的。
Yeah.
让我先坦白一下。
So let me start by confessing.
我天性乐观,所以你可能需要对我的所有说法打点折扣。
I am an optimist by nature, So, you may need to take everything I say with a grain of salt.
然而,我认为这种富有的美国人无需缴税的体系之所以出现,是因为我们独特的历史以及遗产税的特定脆弱性。
However, I think that this system of nonpayment by wealthy Americans came about because of our particular history and particular vulnerabilities of the estate tax.
我们曾经有一个体系,其中所得税并不完善,遗产税本应作为补充,但在20世纪90年代初对遗产税的攻击如此有效,以至于就连民主党人都不敢采取任何措施关闭这些漏洞,因为许多美国人认为这是一种不公平的双重死亡税。
So, we had a system where the income tax was incomplete, the estate tax was supposed to be a backup, the assault on the estate tax in the early 1990s was so effective that even Democrats were afraid to do anything to close the loopholes because so many Americans saw it as an unfair double death tax.
我认为,如果我们能拥有一个更清晰的体系——比如取消遗产税,只保留所得税系统,那么要蒙蔽公众就困难得多了。
I think if we had a cleaner system that we could easily have, we get rid of the estate tax, we have an income tax system, it gets a lot harder to pull the wool over the eyes of the public.
所以我不认为富人总能控制一切,总能得到他们想要的东西。
So I don't think it's the case that rich people can always control, always get what they want.
我认为我们现在正处在一个前所未有的压力时期,这种状况正在发生。
I think that we are living in a moment now where there's more pressure than ever for this to happen.
这个加州财富税,对吧?它的出现是因为公众普遍意识到,我们有一大批超级富有的人掌控着国家大部分财富,比自1920年代以来任何时期都多。
This California wealth tax, right, this is happening because the public has become broadly aware that we've got a lot of super rich people that control massive amounts of the country's wealth, more than they've held, I think, since the 1920s.
相当可观的份额。
Significant amount.
我认为目前美国最富有的1%人群掌握了全国31.7%到32%的财富。
I think it's currently 31.7, 32% of the country's wealth is held by the richest 1% of Americans.
与此同时,这些人最近似乎都没有为自己赢得什么荣耀。
And at the same time, none of them seem to be wrapping themselves in glory these days.
对吧?
Right?
如果我们回溯二十年,我们的富人曾做过许多了不起的事情。
If we go back twenty years, we had all sorts of amazing things being done by our rich people.
在21世纪初出版了一本名为《慈善资本主义》的书,副标题是‘富人如何拯救世界’。
And there was a book that came out in the early two thousands that was called Philanthrocapitalism, and the subtitle was how the rich can save the world.
当时这并不被认为是疯狂的。
And this was not seen as insane.
你能想象今天会有一本书叫‘富人如何拯救世界’吗?
Can you imagine a book today, how the rich can save the world?
我从事的是专业意见行业。
I I'm in the professional opinion business.
我可以想象任何事情。
I can imagine anything.
是的。
Yeah.
但当时人们竟然会认为这种观点能被公众接受——而它确实在那个时代被接受了。
But the idea that someone would think that this would land with the public, which it did in that era.
对吧?
Right?
超级富豪们能做很多事情。
The super rich, they are they are they can do so many things.
我们应该把社会的所有问题都交给他们。
We should hand over all of society's problems to them.
我的意思是,今天很多人会觉得这种想法可笑。
I mean, I think a lot of people would find that laughable today.
我认为这个评论所指的是一些人想对富人征税,是因为他们想惩罚富人。
I think something that comment is getting at is sometimes people wanna tax the rich because they wanna punish them.
这就像他们
It's It like they
不喜欢富人。
don't like the rich.
他们现在确实不喜欢富人。
They definitely don't like the rich right now.
对吧?
Right?
我非常理解你所提出的观点。
I'm very sympathetic to the the argument you're making.
但另一方面,这会把很多事情牵扯到道德评判上,而我的看法是,无论谢尔盖·布林处于‘不作恶’的时代,还是完全认同的时期,他都应该为那笔财富缴税。
And on the other hand, that then sort of winds a lot of things up in moral judgment, when sort of my view is that Sergey Brin should have to pay taxes on that wealth no matter if he's in the don't be evil era or in the I totally agree.
时代。
Era.
我完全同意。
I completely agree.
我认为,把焦点放在富人是坏人、因此我们应该对他们征税上,是个巨大的错误。
I think it is a big mistake to focus on rich people are bad, and therefore, we should be imposing taxes.
因为我认为这很糟糕的原因是,当我们把讨论转向富人是好是坏时,我们就忽略了最重要的一点:最富有的美国人已经被排除在我们的税收体系之外。
Because the reason I think it's bad is because when we move the conversation to whether rich people are good or bad, we are not focusing on the fact that the richest Americans have been written out of our tax system.
这就像我们有一个制度,规定住在宾夕法尼亚州的人不用缴税。
It's as if we had a system that said people who live in Pennsylvania don't have to pay tax.
对吧?
Right?
我们不应该进行这样的讨论,说宾夕法尼亚州的一些人是好人。
We shouldn't have a discussion that says, well, some of the people in Pennsylvania are good.
也许他们不缴税也没关系。
Maybe it's okay they don't pay tax.
对吧?
Right?
从原则上看,这是错误的。
It's wrong as a matter of principle.
这是错误的,因为我们需要他们的钱。
It's wrong because we need their money.
从公平的角度看,这是错误的。
It's wrong as a matter of fairness.
这在很多方面都是错误的。
It is wrong for so many reasons.
我认为主要问题回到你之前的问题,即公众被误导,以为富人缴纳的税比实际要多。
And I think the big problem is goes back to your earlier question, which is that the public is misled into thinking the wealthy are paying more taxes than they are.
这1%的人缴纳了40%的税,对吧?但大多数公众并不知道,最富有的美国人通过将应税收入规避掉来逃税。
With this 1% paying 40%, right, most of the public doesn't know that the wealthiest Americans are able to avoid taxes by paying taxable income.
如果他们知道了,就不会希望维持这样的制度。
And if they knew, they wouldn't want that system.
我所听到的这些,和我认识的那些参与设计财富税的人告诉我的一致,但我感到非常沮丧,因为这看起来本应该是可以实现的。
I find what you're telling me here to both track what people I know who have worked on crafting wealth taxes tell me, but but I find very frustrating, which is that it seems like it should be possible.
嗯。
Mhmm.
但你越深入研究,就会发现它越困难,不仅在宪法层面是一个问题,而且持续评估资产价值、担心人们将资产转移到更难估值的类别中,也成了难题。
And the more you get into it, the harder it becomes, both constitutionally, which is one dimension of it, but the the valuing and the continuous valuing and the worrying about people moving things into harder to value assets becomes a problem.
而且我
And I
不知道。
don't know.
自从我开始了解税收以来,就一直希望实行财富税。
I've wanted there to be a wealth tax as long as I've been aware of taxation.
如果我们无法实施类似措施,我认为我们正在失去的东西,值得明确指出的是:财富创造权力。
And the thing that I feel we're losing if we can't do something like it, which I just think is worth naming, is that wealth creates power.
它会带来巨大的权力。
It creates a tremendous amount of power.
在我们所处的这个时代,富人并不一定对利用财富施加影响力感到羞怯。
And we're operating in this era when it's not that the rich were necessarily the super rich so shy about using their wealth to to wield power.
我的意思是,你提到了由18个最富有家族大力资助的反遗产税运动,但你现在看到像埃隆·马斯克这样的人直接参与的程度,确实如此。
I mean, you mentioned the anti estate tax campaign that was heavily funded by 18 of the richest families, But the level of, like, direct engagement that you're seeing now from people like Elon Musk Yeah.
他们正在切实推动一种长期存在的担忧:如果财富过度集中,就会导致政治权力的不可控集中,没错。
Like, they are really making the long running fear that if you have enormous wealth concentrations of wealth, you will have, like, unmanageable concentrations of political power Mhmm.
显而易见。
Manifest.
你可以设计一套税收制度,我们稍后会讨论,最终对这些财富征税。
And you can design, and and presumably, we'll we'll talk about it, a tax code, you know, that taxes this money eventually.
但它并没有解决政治权力的问题,而很多人原本希望税收制度能解决这个问题。
But it it doesn't solve the political power question in a way that I think a lot of people want to use a tax code to do so.
我很想知道你是怎么看待这个问题的。
And I'm I'm curious how you think about that.
是的。
Yeah.
我认为这是一个真正的问题,也是一个真正的担忧。
I think it's a real problem, and it's a real concern.
我的意思是,掌控巨额财富的人在我们的社会中拥有巨大的权力。
I mean, people controlling massive amounts of wealth have tremendous power in our society.
因此,我理解在某种理想化的世界里,足够强大的财富税能够显著削减最富有人群的财富,使其降至不再拥有这种权力的水平。
And so and I understand that in some fantasy world, a powerful enough wealth tax will be enacted to make a sufficient enough dent in the wealth of the wealthiest people where it is brought down to a level where they no longer have this power.
然而,就我所见,这看起来就像一个幻想世界。
However, from where I sit, that just looks like a fantasy world.
这不会发生。
That's not gonna happen.
它不会产生足够的影响。
It's not gonna be significant enough.
公众一般不会接受这一点。
The public isn't gonna buy it generally.
我认为公众一般不会接受的原因之一,是我们之前提到过的一点:如果这种税是专门针对最富有的人,仿佛我们必须惩罚他们,我认为全国上下并不都认同这种观点。
And I think one of the reasons the public isn't gonna buy it generally is because of something we talked about earlier, which is that to the extent it is a special tax focused on the richest people, like we have to punish the richest people, I don't think everybody in the country agrees with that.
很多国人认为,那些积累财富的人是因为他们做出了了不起的成就。
A lot of people in the country think that people who have acquired their wealth have done so because they've done great things.
他们创办了优秀的企业,有时确实如此。
They've started great companies, and sometimes they have.
有时他们确实做出了伟大的贡献。
Sometimes they have done great things.
所以,这种做法过于一概而论了。
And so, it paints too broad a brush.
问题在于,我们必须生活在真实的世界上。
The problem with it is that we have to live in the world that we actually live in.
而在我们真实所处的世界里,我不认为这会是一个能实现该目标的解决方案。
And in the world we actually live in, I don't see that as being a solution that's gonna deliver that result.
我认为,确保最富有的人缴税还有另一个原因,那就是人们会效仿他人的行为。
I think there's also another dimension to why you should want to make sure the richest people are paying taxes, and that is that people do what other people do.
是的。
Yes.
我在读你的书并为这次对话做准备时,一直在思考这个问题。
I was thinking about this while reading your book and and preparing for this.
我缴税。
I pay taxes.
我不介意缴税。
I don't mind paying taxes.
我认为这是生活在社会中的一部分。
I think that is part of living in a society.
生活在美国对我而言很好。
Living in America has been good to me.
那些比我更有钱的人不缴税,这让我很生气。
It does piss me off that people above me are not paying taxes.
是的。
Yeah.
我有时听到的是,他们在谈论那些奇怪的避税策略,我不是在说那些亿万富翁,而是那些花更多时间研究逃税的人。
And what I hear sometimes, I'm talking about their weird strategies, and I'm not talking about set to billionaires here, just, you know, people who spend more time on tax avoidance.
你会想,哎,我是不是个傻瓜?
You think, oh, like, am I being a sucker?
是的。
Yeah.
而在这些极高收入阶层中,最富有的人让下面的富人觉得自己是傻瓜,而人们都不想当傻瓜。
And the fact that at these very high levels, the very richest are making the rich people right underneath them feel like suckers, people don't wanna be suckers.
他们不想觉得别人占了便宜,而自己却没有。
They don't wanna feel that other people are getting a deal they're not getting.
是的。
Yeah.
一方面,你可能会想,如果这种现象能促使更多富人倡导更公平的税收制度就好了,但事实似乎并非如此,它并没有阻止上面的人继续这样做。
Now on one hand, you might think it would be good if this made more rich people, you know, advocate for a better tax system, which it doesn't seem to have done to to shut down the ability of people above them to do this.
但我确实认为这非常具有腐蚀性,我完全同意。
But I do think that it's very corrosive I totally agree.
社会凝聚力,会让人感到有人得到了远比你更好的待遇。
Social solidarity, to have this sense that there are people out there getting a way better deal than you are.
我再同意不过了。
I couldn't agree more.
这就是为什么我认为很多问题都与人们感受到你之前提到的这一点有关。
And that's why I think a lot of that has to do with the fact that people feel like this point that you made before.
普通民众总是会吃亏。
Well, the regular people are always gonna lose out.
富人总是能如愿以偿。
The rich are always gonna have their way.
事情总是对他们有利。
It's always gonna be to their advantage.
但情况并不总是如此。
But that is not always the case.
因此,我认为回顾历史上的不同时期非常重要。
And that's why I think it's important to think back in history to different times.
我认为特别有趣的一个时期是1986年的税制改革法案。
So one of the times I think is particularly interesting is the tax reform act of 1986.
那是我们最后一次真正实现有意义的税制改革。
That is the last time that we actually have had any really meaningful reform in the tax system.
那是里根总统任内发生的,虽然有些出人意料,但它采纳了两党都曾支持的原则。
It was under President Reagan, was kind of surprising, but it adopted principles that had been around under both parties.
当我们谈到高收入者难以避税时,这正是1986年改革所带来的变化。
And what it did when we talk about high income earners and the inability of high income earners to avoid taxes, that is because of changes that occurred in 1986.
在1986年之前,我们有一个蓬勃发展的避税产业。
Prior to 1986, we had a flourishing tax shelter business.
当时,像高薪外科医生这样的高收入者根本不用为收入缴税,因为他们可以通过投资避税工具,用各种合法手段抵消全部收入。
And high paid your high paid surgeon would have not paid taxes on their income because they would have been able to do their invest in tax shelters and offset all of their income bylaws.
关于二战后中期极高的所得税税率。
About the very high mid century World War two post World War two income tax rates.
但我认为这很重要,因为到1986年时,这些税率在图表上看起来并不像实际那么高。
But I think this is important because some of these were not actually as real by 1986 as you look on a chart.
没错。
Exactly.
所以你虽然有很高的税率,但高收入者却大规模避税。
So you had these high rates, but you had massive avoidance by high income earners.
1986年的法案做了一件非常有趣的事,我认为我们今天也该这么做,那就是通过取消这些避税工具来拓宽税基。
And the 1986 act did something very interesting, and I think something that we should be doing today, which is it broadened the base by getting rid of those tax shelters.
他们成功地消除了这些避税工具,以至于今天我们已经不再有它们了。
And they so effectively got rid of those tax shelters that we don't have them today.
对吧?
Right?
我们现在的高收入人群,那些高薪人士,都在缴纳大量的税款。
Our high income people, people with lots of salaries, they are paying lots of taxes.
他们几乎没有理由或途径来避税了。
There's really very little reason or ways for them to avoid taxes.
他们是一个政治上很有影响力的群体。
And they were a politically powerful group.
所以,如果你有真正关心并推动这件事的人,这是可以实现的。
So it can happen if you have people that really care about making it happen.
这并不是不可能做到的。
It's not like it's impossible to make happen.
我认为,这才是唯一的出路。
And I think that that is the only way to go.
我们国家唯一的前进方向,是找到一种公平的税收制度。
Our only way forward as a country is if we figure out how to have a fair tax system.
我认为,这种紧迫性不仅是道德上的要求,也是财政上的必要,因为如今我们的国家债务如此庞大,利息支出已成为仅次于社会保障和医疗保险的第三大开支。
And I think that imperative, that moral imperative is also a financial imperative because right now, our national debt is so great that interest payments on the national debt are the third highest expense after Social Security and Medicare.
今年我们仅用于偿还债务的支出就高达一万亿美元,超过了军费开支。
We are spending a trillion dollars just to carry the debt this year, more than we're spending in the military.
你知道,这是不可持续的。
And, you know, that is not sustainable.
所以我们必须找到一种方法,让所有人都纳入税收体系。
So we're gonna have to find a way to bring everybody into the tax system.
接下来我会提出最后一个问题。
And then I'll ask our final question.
您能为观众推荐三本书吗?
What are three books you recommend to the audience?
第一本书是蒂姆·吴的《抽取时代》。
The first book is The Age of Extraction by Tim Wu.
这是一本极佳的书,探讨了我们许多曾经为世界带来巨大福祉的公司,如今却不再创造财富,而是进行财富掠夺。
This is a fantastic book that talks about how many of our companies that used to do a lot of good for the world are now rather than producing wealth, they are doing wealth extraction.
这对我们所有人来说都不是好事。
And that's not good for any of us.
这与对个人和企业征税的问题密切相关。
And it's relevant for these issues of taxing individuals and taxing companies.
另一本是加里·格尔斯特尔的《新自由主义秩序的兴衰》的兴衰。
The other is the book, The Rise and Fall of the Neoliberal Order by Gary Gerstle.
我喜欢这个。
And I like this.
所有往期节目的嘉宾。
All past guests of the show.
蒂姆·吴,加里,是的。
Tim Wu, Gary Yeah.
我非常喜欢是的。
I love yeah.
这些书都很棒。
These are great books.
好的。
Okay.
这是一本很棒的书。
That is a fantastic book.
我要说,书名听起来有点吓人,但书本身非常易读。
And I will say that the title is a bit daunting, but the book itself is so readable.
它提出了一个极其重要的观点:过去,这个国家对政府与市场角色有着一种截然不同的看法。
And it makes this incredibly important point that the country used to have one vision of the role of government versus markets.
而如今,随着新自由主义的兴起,这种观点已转变为一切应让市场自由运行。
And now we through the rise of neoliberalism, it now switched to this thing of it's all about let the market run free.
但关键在于,这生动地展现了可能出现的剧烈转变。
But the point is that it is a fantastic illustration of the swings that can occur.
正如我们在最近几年清晰看到的那样,钟摆总是会向两个方向摆动。
And pendulums swing both ways as we have seen loud and clear in recent years.
我认为,这真是一个很好的提醒:当人们为当下的种种问题感到绝望时,恰恰也是钟摆可能回摆、更好制度得以确立的契机。
And I think it's a really good reminder that when people despair of all of the problems of the day, there is an opportunity for pendulums to swing back and for better systems to take hold.
最后一本书是小说《十字路口》,作者是乔纳森·弗兰岑。
And the last book is a book of fiction, the book Crossroads by Jonathan Franzen.
小说在任何时候都是绝佳的避风港,尤其在当下,它让我们得以探索超越我们现实世界的其他可能性。
Fiction at any time and particularly in these times is just a a fantastic place to live to explore other things than the world that we're living in.
我认为,乔纳森·弗兰岑在呈现人物内心心理戏剧方面,几乎胜过我所知的任何人。
And I'd say Jonathan Franzen, better than almost anyone I know, presents people's internal psychological dramas.
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