民主党在中期选举中大获全胜，重燃了在全国层面向富人征税的势头。预计将重新掌控参议院财政委员会的参议员罗恩·怀登（民主党-俄勒冈州）已经向亿万富翁发出了警告。委员会目前已有多项提案，包括关闭“载息分成”税收优惠漏洞、对大型信托资产征税等措施。
Democrats' sweeping midterm victories have renewed momentum for taxing the wealthy on a national level. Sen. Ron Wyden, D-Ore., who is set to retake control of the Senate Committee on Finance, has already put billionaires on notice. Several proposals are already before the committee, including measures to close the carried-interest tax break and impose taxes on large trust assets.
怀登周三上午在一份声明中表示：“在税收问题上，委员会将加倍努力，确保亿万富翁支付其应尽的公平份额，并追究偷税漏税者的责任。民主党将主导一项以美国家庭为优先、要求超级富豪和企业支付其应尽公平份额的税收议程。”
"On taxes, the committee will redouble its efforts to ensure billionaires pay their fair share and hold tax cheats accountable. Democrats will spearhead a tax agenda that puts American families first and requires the ultra-rich and corporations to pay their fair share," Wyden said in a statement Wednesday morning.
税务律师告诉CNBC，由于民主党赢得的席位不足以推翻唐纳德·特朗普总统的否决，拟议的财富税和其他增税措施不大可能成为法律。不过，他们表示，这些措施值得关注，因为它们塑造了该党的议程，为下届总统大选做准备。
Tax lawyers told CNBC that proposed wealth taxes and other tax hikes are unlikely to become law because the Democrats have not won enough seats to overcome a veto from President Donald Trump. However, the measures are worth monitoring as they shape the party's agenda heading into the next presidential election, they said.
Evercore Wealth Management合伙人兼财富规划全国总监贾斯汀·米勒表示：“这些提案不一定是未来两年能通过的东西。但如果两年后政府更迭，它们确实能让你了解下届政府可能会拿上台面讨论什么。”
"The proposals are not necessarily anything that will pass over the next two years. But if there is an administration change two years from now, they do give you an indication of what might be what might be on the table during the next administration," said Justin Miller, partner and national director of wealth planning at Evercore Wealth Management.
以下是参议院财政委员会目前掌握的三项税收提案，在“蓝色海啸”之后可能获得推进动力。
Here are three tax proposals sitting with the Senate Committee on Finance that could gain traction after the blue tsunami.
《终止“利息分成”漏洞法案》 4月，怀登和缅因州独立党籍参议员安格斯·金提出了一项法案，旨在取消“利息分成”享受的优惠税收待遇，这是华尔街广受青睐的一项减税政策。根据现行法律，如果投资持有至少三年，基金管理人可以让其分得的基金利润按较低的资本利得税率纳税。《终止“利息分成”漏洞法案》将把投资利润作为普通收入征税，并要求基金管理人每年确认并就视同薪酬缴税，而不是将纳税义务推迟到基金实现收入时。
Ending the Carried Interest Loophole Act In April, Wyden and Sen. Angus King, I-Maine, introduced a bill eliminating the preferential tax treatment of carried interest, a popular Wall Street tax break. Under current law, fund managers can have a share of a fund's profits taxed at the lower capital-gains rate if the investments are held for at least three years. The Ending the Carried Interest Loophole Act would tax investment profits as ordinary income and also require fund managers to recognize and pay tax on deemed compensation annually, rather than deferring taxes until the fund realizes income.
据霍兰德与奈特律师事务所合伙人、前财政部和参议院财政委员会税务顾问约书亚·奥丁茨介绍，近二十年来，两党议员都曾提议改变“利息分成”的征税方式。特朗普总统曾多次批评该条款，他在2016年竞选总统期间表示，这对美国工人“不公平”。奥丁茨预计，随着国会面临巩固社会保障信托基金的压力——该基金预计将在2032年底耗尽储备金——“利息分成”将受到更多审视。不过，他认为取消这一税收优惠更有可能通过预算协调法案实现，而非作为单独法案通过。
Lawmakers on both sides of the aisle have proposed changing the taxation of carried interest for nearly two decades, according to Holland & Knight partner Joshua Odintz, a former tax counsel at the Department of Treasury and the Senate Committee on Finance. President Trump repeatedly criticized the provision, saying during his 2016 presidential campaign that it was "unfair to American workers." Odintz said he expects more scrutiny of carried interest as Congress faces pressure to shore up the Social Security trust fund, which is expected to run out of reserves by the end of 2032. However, he thinks it is more likely that the tax break will be eliminated as part of a budget reconciliation bill rather than a standalone bill.
“我认为，像‘利息分成’这样的问题，必须放在更大规模的税收法案背景下来解决，因为议员们很难说：‘不，我要仅仅为了这一个问题挺身而出，让法案胎死腹中，’”他说。“当存在一系列权衡取舍时，情况就会容易得多，议员们可以指出不同的权衡，说：‘看，我争取到了这个。我想我不得不放弃那个，但总体而言，这对我的选区更有利。’”
"I think an issue like carried interest have to be addressed in the context of a larger tax bill, where it's challenging for members to say, 'No, I'm going to stand up just on this one issue and crater a bill,'" he said. "It's much easier when there are a series of trade-offs, and members can point to the different trade-offs and say, 'Look, I got this. I guess I had to give up that, but on net, this is better for my jurisdiction.''"
《公平信托财政责任法案》 参议员帕蒂·默里（民主党-华盛顿州）提出了一项法案，针对用于转移资产同时将遗产税和赠与税降至最低或予以规避的信托。《公平信托财政责任法案》对超过5000万美元的信托资产设定累进年度税，税率对超过10亿美元的资产上升至3%。该法案还将建立预扣抵免制度：每年缴纳的税款将记入账户，并在资产日后转移或信托终止时，抵扣遗产税或跳代税。任何未用于抵扣遗产税的抵免额可予退还。
Fair Trusts for Fiscal Responsibility Act Sen. Patty Murray, D-Wash., introduced a bill targeting trusts used to transfer assets while minimizing or avoiding estate and gift taxes. The Fair Trusts for Fiscal Responsibility Act sets a graduated annual tax on trust assets exceeding $50 million, with the rate rising to 3% for assets above $1 billion. It would also create a withholding-credit system: taxes paid each year would be tracked in an account and credited against estate or generation-skipping taxes when assets are later transferred or the trust ends. Any unused credit against estate taxes could be refunded.
“这是值得关注的事项，因为如果它获得关注并推进，将从根本上改变超高净值人群的遗产规划，”阿克曼律师事务所全国税务业务组合伙人兼主席大卫·布鲁姆表示。
"This is something that should be watched because if it gets traction, it would fundamentally change estate planning for ultra-high-net-worth individuals," said David Blum, partner and chair of Akerman's national tax practice group.
米勒表示，考虑到实施的复杂性，他怀疑该法案能否通过。他认为，美国更有可能效仿英国和加拿大的做法，每隔一定年限对信托持有的资产征税一次。在英国，遗产税每10年征收一次；加拿大则对大多数个人和家族信托实施21年规则。
Miller said he is skeptical that the bill would pass given how complicated it would be to implement. He thinks it is more realistic that the U.S. would follow the examples of the United Kingdom and Canada and periodically tax assets held in trust every set number of years. In the U.K., an inheritance tax is levied every 10 years, and Canada imposes a 21-year rule on most personal and family trusts.
2026年《通过对被忽视债务设立新高收入义务来重新分配数十亿美元（罗宾汉）法案》 几位即将上任的民主党参议员，包括詹姆斯·塔拉里科和阿卜杜勒·埃尔-赛义德，已承诺要遏制亿万富翁拉里·埃里森和埃隆·马斯克所采用的“买入、借贷、死去”避税策略。富有的创始人和投资者以股票为抵押借款，从而在不卖出股票、不触发资本利得税的情况下获得现金。如果他们将资产持有至去世，继承人还可以按上调后的税基获得这些资产，使累积的收益无需纳税。
Redistribution Of Billions by Instituting New High-income Obligations on Overlooked Debt (ROBINHOOD) Act of 2026 Several incoming Democratic senators, including James Talarico and Abdul El-Sayed, have pledged to curb the "buy, borrow, die" tax strategy practiced by billionaires Larry Ellison and Elon Musk. Wealthy founders and investors borrow against their stock to access cash without selling shares and triggering capital-gains taxes. If they hold the assets until death, heirs can also receive them with a stepped-up tax basis, leaving the accumulated gains untaxed.
参议院的《罗宾汉法案》由亚利桑那州民主党参议员鲁本·加列戈于6月提出，将要求超级富豪借款人就其用作抵押的部分长期资产缴纳资本利得税。该法案将适用于资产至少10亿美元或年收入超过1亿美元的个人，且仅在资产未实现收益至少与贷款金额相当的情况下适用。
The Senate's ROBINHOOD Act, introduced by Sen. Ruben Gallego, D-Ariz., in June, would make ultra-rich borrowers pay capital-gains taxes on selected long-term assets they borrow against. It would apply to individuals with at least $1 billion in assets or more than $100 million in annual income, and only when the assets' unrealized gains are at least as large as the loan.
众议院一项相关法案由纽约州民主党众议员丹尼尔·戈德曼提出，将对收入超过40万美元的借款人某些以资产为抵押的贷款征收20%的税。众议院法案豁免了若干类型的贷款，包括抵押贷款和保证金贷款。
A related House bill, introduced by Rep. Daniel Goldman, D-N.Y., would impose a 20% tax on certain loans backed by assets for borrowers with income over $400,000. The House bill exempts several types of loans, including mortgages and margin loans.
米勒表示，与占据头条的全面财富税提案相比，这些法案范围更窄，实施起来也容易得多。他说，尽管这些“买入、借贷、死去”法案受到的关注较少，但通过的可能性更为现实。
Miller said these bills are narrower and far easier to implement than the sweeping wealth tax proposals that dominate headlines. While these "buy, borrow, die" bills have gotten less attention, they have more realistic odds of passing, he said.
尽管未来两年税收政策很可能陷入僵局，奥丁茨建议高净值纳税人主动采取行动。
While tax policy gridlock is the likely outcome for the next two years, Odintz advised high-net-worth taxpayers to be proactive.
“我认为，相关选民如果发现立法存在与其所述目的不符的非预期问题，应当与怀登及其工作人员沟通。我认为现在就介入比以后再介入更值得，”他说。“如果2029年白宫由民主党人入主，且民主党控制参众两院，那么我们可能会看到一项快速推进的和解法案，其方向与《One Big Beautiful Bill Act》和《减税与就业法案》相反。”
"I think concerned constituents should engage with Wyden and his staff if they see problems that were unintended based on the stated purpose of legislation. I think it's worth coming in now rather than later," he said. "If in 2029 there's a Democrat in the White House and Democrats control both houses, then we could see swift movement for a reconciliation bill that goes in the opposite direction of the OBBBA and TCJA."