Or am I missing something where those bottom 98% of estates gain anything from this bill? -- Nathan
YOur description is accurate. In isolation, the change is a tax increase, but its incidence would mirror that of the existing capital gains tax, which is strongly progressive.
The Right likes to quote statistics about the number of persons who pay *some* capital gains tax, in keeping with the dispersion of stock ownership, but the bulk of actual revenues are surrendered by higher-income persons.
We are talking about two different taxes here. The carry-over pertains to the income tax. The 'bottom 98%' of estates is not the same as the bottom 98 percent in terms of income. While most of the top two percent of estates are probably in the top one or two percent in terms of income, many in that same group who did not receive an estate are high in terms of other income.
Most recent work on this is by Leonard Burman in a book and also in a paper that can be downloaded free from the Urban Institute web site.