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I don't think unrealized gains need to be taxed if the collateralization of those gains is taxed. That way any liquidity event is taxable.I don’t disagree with you there.
There are lots of ways to tax rich people more besides just trying to tax their unrealized gains, which has all kinds of pitfalls involved. I’m unclear if you even think taxing unrealized gains is a good idea or not, so I’m not saying you advocated for it.
If the money stays invested totally and not touched, it doesn't need to be taxed. Gonna be hard for the billionaires to eat on invested money though. Tax the earnings, tax rhe dividends, and tax any loan events against that equity.