What about the approach I posted here recently? Wouldn't it bring in plenty of revenue and simplify life (and death)? Eliminate the estate tax but reduce the benefit of step-up basis at death by requiring beneficiaries to carry a tax basis of half the value of the assets on the date of death unless the beneficiary can prove that the decedent's basis was higher. For most types of investment assets, this should eliminate any need to search records more than a decade or so old. Personal use assets of the type that wear out could be excluded from this provision and carried at market value on the date of death up to $100k or so total. With this compromise, the beneficiary is not forced to sell to pay taxes. Family farms and businesses can be passed on forever, and the tax will only become due when the property is sold to new owners. The tax rate will be at most half the capital gains rate, but there will be no tax exemption or at least one much smaller than today's $3.5 million.