WASHINGTON – ADW Capital Partners appears to be the kind of hedge fund that Democrats on the Senate Finance Committee would like to tax more heavily: small but rapidly growing, with $ 330 million in assets, a Delaware incorporation but doing business in Florida, and an offshore “feeder” company protecting some of its clients from US taxation.

It’s no wonder, then, that its owner, Adam Wyden, has been vocal and vocal critic of the tax increases pushed by the committee chairman, Senator Ron Wyden of Oregon – his father.

The public dispute between son and father over elder Mr. Wyden’s relentless efforts to tax the wealth of the super-rich and close loopholes that have particularly benefited the wealthiest financiers has accentuated a particular phenomenon that has contributed to protect American billionaires. Whenever Congress weighs on them, the rich rush to interfere with the fabulously rich.

Adam Wyden, 37, has made it clear he doesn’t want to push his family dispute too far.

“The problem is bigger than my father. I’m not interested in discussing anything personal, ”he said in a brief phone call before declining to go any further. He said he was “not a Trumper” and “not an Ocasio” – referring to New York Representative Alexandria Ocasio-Cortez, an icon of the Democratic left. He’s a libertarian, he said, raised in Washington, DC, who moved to Florida “to get away from the struggle for food.”

But he made public his grievances against his father’s proposals, in an appearance last month on CNBC which he recommended watching, and in a tweet responding to Elder Wyden’s claim that Elon Musk and other billionaires shouldn’t decide to pay taxes based on a Twitter poll.

“Why does he hate us / the American dream so much?!?!?!?!” Adam wyden said in the Twitter post last month. “The reality is, most lawmakers never built anything… so I guess it’s easier to mindlessly and haphazardly try to demolish things. “

His father would like to avoid the subject all together.

“He doesn’t tell me about his business, and I don’t tell him about mine,” Senator Wyden, 72, said in an interview on Wednesday.

But as President Biden’s social safety net and $ 2.2 trillion climate change bill languished in the Senate, Mr Wyden kept alive the proposals his son spoke out against. The annual wealth gains of about 700 US billionaires would be taxed, some of whom have shown in a series of ProPublica reports to have paid a tiny fraction of their wealth in taxes, while others have paid no income tax at all. The proposal would raise $ 557 billion over 10 years and turn the Build Back Better Act into a real deficit reducer.

Another would change the rules that business partnerships have used to avoid taxation and evade Internal Revenue Service audits. Yet another would close the so-called deferred interest loophole, which allows some hedge fund and private equity managers to claim the fees they charge clients as capital gains, not income – and pay much lower tax rates.

Monte A. Jackel, partnership tax expert and advisor to tax firm Leo Berwick, said Adam Wyden would undoubtedly pay higher taxes under some of his father’s proposals. The senator’s efforts to close the deferred interest loophole would mean that income on which his son now pays a 20% tax rate would be taxed up to 37% annually.

Efforts to shut down the offshore partnerships could indirectly harm young Mr Wyden, costing him a few clients, Mr Jackel said. He highlighted the structure of Mr. Wyden’s fund, which includes a “master fund” partnership in the United States and a foreign “offshore feeder” company, which allows tax-exempt and foreign investors to avoid tax. American.

But Adam Wyden is hardly one of the big whales that most Senate Democrats consider paying for their expenses. With three employees, just over 150 investors and $ 329 million in assets under management, ADW Capital Partners is a success but not a titan. Citadel Advisors, a large hedge fund, has $ 235 billion in assets and more than 2,000 employees.

“At the maximum,” Adam Wyden could have adjusted gross income of $ 12 million, said Steven N. Kaplan, professor of finance at the Booth School of Business at the University of Chicago.

He would in no way be affected by his father’s wealth tax, which would only be levied on people with $ 1 billion in assets or $ 100 million or more in income over three consecutive years. It could be affected by a provision in the House-passed version of the Social Policy Bill, which would impose a 5% surtax on income over $ 10 million. But his father has said he would much rather hit billionaires than millionaires, and complained that the House plan taxes NBA players while letting team owners off the hook.

Yet Adam Wyden barged in defending one of his father’s real targets, Mr. Musk, after the Tesla founder asked Twitter followers if he should sell shares in the company and pay taxes on it. these, then insulted Senator Wyden with what sounded like a slight vulgarity.

“Fortunately, I think I can make up ‘the investment gains’ faster than my dad and his pals can take it away,” Wyden wrote.

Praised on CNBC’s “Squawk Box”, it developed on air. “Amazon, Netflix, Google, Tesla: I mean, we’re the envy of the rest of the world,” he said. “People come to this country to build amazing businesses, and I want that to continue. “

Without referring to his son, the elder Mr Wyden suggested a possible reason for his position: “Many millionaires could perhaps see themselves as the billionaires of tomorrow.

Dennis Kelleher, who heads Better Markets, a group that fights income inequality, said mobilizing the small to protect the big “happens all the time.” Small business owners are protesting property taxes they will never pay. Community banks are protesting against regulations targeting the big banks which are their biggest competitors. Minimum wage workers are sort of being presented as the targets of the IRS’s enforcement proposals aimed at the ultra-rich.

“Not only does this skew the discussion about an incredibly important policy,” he said, “but it ends up advancing the interests of this very small number of people and industries who have a grip on public policy. in Washington.”

Adam Wyden is a reluctant rebel. He said he had “no interest in engaging in a Wyden-versus-Wyden story,” and was more interested in talking about his Jewish grandfather who cheated on his medical exam to gain the chance to ‘invade Normandy on D-Day and become a decorated war. hero.

He is hardly the only rich person defending the rich fantastically. The billionaire class has long relied on farmers and ranchers to push back efforts to tax more inheritances. This year, the tactic worked to kill a proposal by Mr Biden that would have valued the inherited assets at their original purchase price, not their value at the time of the original owner’s death.

This “increase” in the value of an inherited asset means that its unrealized lifetime gains are often never taxed, a boon to wealthy heirs, protected in Washington by those considered politically untouchable. This includes family farmers, who are actually unlikely to be affected given that Democratic proposals include protections for farms, ranches and small businesses.

Two former Democratic senators from rural states, Max Baucus of Montana and Heidi Heitkamp of North Dakota, lobbied against the Biden proposal and quickly won over Senator Jon Tester, the current Democrat from Montana, who killed him in October on behalf of “our family”. farms, ranches and small businesses.

Senator Wyden insists he is not giving up.

“Next year when people sort this out, after hearing time and time again that billionaires pay little or nothing,” he said, they need to see that changed. He added: “We will stay there.”