The ultrawealthy always get out of this stuff through the creation of trusts, foundations and gifts.
I would impose a wealth tax instead, for the top 0.3% wealthiest of 6%, 4%, and 2% for the top 0.1%, 0.2% and 0.3% respectively. The revenue from this would go directly to pay down the national debt. If and when it is 15% of GDP that tax will be suspended. And trusts would not be protected from this. With such a tax, there is no reason for an estate tax.
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