Memo for Ultras
A PERSONAL MEMO
TO ULTRAS
From ORANS — in plain language, with respect
orans.org
This memo is addressed directly to you — the individuals the Billionaire Program calls Ultras. We are going to be straightforward with you, because you deserve that and because the stakes are too high for anything else.
You are reading this because your net worth places you above $200 million. That means the Billionaire Program, if enacted, applies to you. We want you to understand exactly what that means, what your choices are, and why we believe voluntary participation is not just in the public interest — it is in yours.
We are not your adversaries. We do not think you are bad people. Most of you built extraordinary things, employed thousands of people, created genuine value, and did so through talent, hard work, and risk-taking that most people will never attempt. We respect that. This memo is not an attack on who you are. It is an appeal to your values, your legacy, and your interests — honestly stated.
FIRST: THE HONEST CASE THAT THIS IS COMING
The political conditions that allowed extreme wealth concentration to exist without constraint are changing. The pace of that change has accelerated dramatically in recent years, driven by two forces that are not going to reverse themselves:
The first is visibility. A generation ago, most Americans did not know or think much about what a billion dollars actually means. Today, they do. The numbers are in the news, in popular culture, in political conversation. The contrast between the life of someone with $50 billion and the life of someone struggling with medical debt or student loans is vivid and widely understood.
The second is AI and automation. The acceleration of wealth concentration through technology is visible in real time. As artificial intelligence reduces the return to labor and increases the return to capital, the economic conditions that generate extreme wealth concentration are intensifying. This is producing a political response that is building, not dissipating.
The Billionaire Program is one proposed response to these conditions. It is a relatively moderate, structured, legally careful response. Other responses that are gaining political traction are less structured and less favorable to you — confiscatory wealth taxes, punitive marginal income tax rates, forced breakups of major companies. The Billionaire Program, by comparison, is designed to achieve the democratizing goal while preserving your fundamental interests as entrepreneurs, innovators, and individuals.
We are not threatening you. We are telling you that the political environment is going to produce a response to extreme wealth concentration, and that having a role in shaping what that response looks like is better for you than having it imposed on you.
SECOND: WHAT THE PROGRAM ACTUALLY MEANS FOR YOU
What You Keep
If you participate in the Program, you permanently retain:
- Your primary home: of any value, completely exempt from the net worth calculation. Your home is yours, regardless of what it is worth.
- Your primary operating business: up to $200 million in equity in your One Entity is completely exempt. If you built a company, you can keep a substantial stake in it.
- $200 million in general net worth: the Wealth Cap, after exemptions. You remain extraordinarily wealthy.
- The ability to grow to $300 million: after completing the Program, your net worth may grow to $300 million before new gifting obligations arise.
- Complete estate planning freedom: you are permanently exempt from federal estate tax. Your entire estate may be bequeathed to anyone you choose, without estate tax.
- A guaranteed floor: your net worth can never fall below $100 million due to market losses. The Treasury backs that guarantee.
The math: $200M in net worth + an unlimited-value home + $200M in your primary business + estate tax exemption on everything + a $100M floor guarantee. You are not being asked to become poor. You are being asked to stop being an oligarch.
What You Give
You give away the portion of your wealth above the Wealth Cap — the portion that, at any realistic rate of investment return, you cannot spend and cannot need. You give it to individual people of your choosing, in amounts up to $15 million per person, unconditionally and irrevocably. You do not give it to government. You do not give it to institutions you cannot control. You give it to people.
You have considerable latitude in choosing who those people are. Up to 40 percent of your total gifts can go to people you know — employees who built your companies, family members, longtime friends and associates. The requirement that 60 percent go to unrelated individuals is served through a verified matching process the FWOA will facilitate. You give at a pace of 10 percent of your excess wealth per year, or $150 million minimum. For most Ultras, the Program plays out over 5 to 10 years.
THIRD: THE REALISTIC ALTERNATIVES
Option 1 — Self-Exile
You may elect permanent self-exile: you leave the United States and never return. You keep all your wealth, all your citizenship rights, your right to vote and make political contributions, and a U.S. passport for travel everywhere except back here.
We want to be honest about what self-exile actually means in practice. For most of you, it means leaving the country where you built your companies, where your families live, where your social and professional networks are rooted, and where your legacy is most meaningful. It means your grandchildren grow up somewhere else. It means being permanently named on the FWOA’s public self-exile list — a roster of Americans who chose their wealth over their country.
Some of you will choose this. We understand that. But we think fewer of you will choose it than you might initially assume, once you have thought through what it actually means for your life.
Option 2 — Noncompliance
If you stay in the United States and decline to participate, the consequence structure of the BPA activates in a carefully sequenced way. You receive a Compliance Order from the FWOA. You have the right to challenge it through full administrative appeal and de novo federal court review. If the court confirms the Order, you face escalating civil penalties: 15 percent of excess wealth in year one, rising to 60 percent by year four. You face contempt proceedings if you defy the court order. And you face referral to the Department of Justice for criminal prosecution of specific acts — not for being wealthy, but for specific regulatory violations.
FOURTH: THE CASE FOR EARLY PARTICIPATION
What You Built Depended on Something
Your wealth was built in the United States. It was built using infrastructure that the public paid for, on legal frameworks that the public established, in markets that the public’s rules made possible, and with employees and customers whose education was publicly subsidized. This is not a critique — it is a description of how capitalism works in a democratic society. The Billionaire Program asks you to acknowledge that interdependence in a tangible way — by redirecting the portion of your wealth that has crossed from personal affluence into structural power.
The Legacy Question
At a certain level of wealth, additional money does not meaningfully change your life. What changes is your legacy — how you are remembered, what your name means to the people who come after you, what role you played in the history of your country at a critical moment.
The Ultras who participate early in the Billionaire Program will be remembered differently than those who resist. The National Benefactors — those who complete the Program — will have their names attached to American public works for generations. They will have been recognized at the White House. The Ultras who choose self-exile, by contrast, will be on a public list. History will remember both groups. Which group do you want to be in?
The First Movers
There is a specific opportunity here for those who move first. The first Ultras to voluntarily enroll in the Billionaire Program — before the legal and social pressure has fully built, when participation is genuinely voluntary and not compelled — will receive a different kind of recognition than those who eventually comply under duress. They will be the founders of a new American tradition. History reserves its greatest recognition for those who see what needs to be done and do it before they have to. We are asking you to be those people.
FIFTH: WHAT WE ARE ASKING
- Read the Billionaire Program Act carefully. Understand what it actually requires, what it leaves you with, and how the enforcement structure works. Make an informed judgment, not a reflexive one.
- Talk to your advisors about the realistic legal and financial consequences of each option — participation, self-exile, and noncompliance. Make sure those conversations are honest about the long-term trajectory of each path.
- Think about your legacy. Think about what you want your name to mean in 50 years. Think about the country your children and grandchildren will live in, and what role you want to have played in shaping it.
- Consider reaching out to ORANS at orans.org if you have questions, concerns, or want to discuss the Program in more detail. We will engage with you honestly and respectfully.
The Billionaire Program is not designed to punish you. It is designed to give you an honorable, structured way to do something historic — to be part of the generation of Americans who chose to share their extraordinary success with the country that made it possible.
We hope you will choose to participate. We believe, in the end, that most of you will.
With respect,
ORANS
orans.org