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What evidence do you have that people borrow against assets as some tax avoidance strategy? What are the details of this brilliant, often repeated plan? In particular, where do you get interest rates that are low enough to make it worth it to avoid capital gains even with an asset that's grown 100x over its cost basis (and are you accounting for reinvestment of income that can't indefinitely defer taxes, creating regular tax lots with higher basis that you could sell first)? e.g. are they getting better interest than SOFR somewhere?
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So why isn't the suggestion to tax the loan instead of the asset (that is 10x more volatile than say property)?
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That may be a perfectly viable solution. Seems like an easier path to me, at least. But the point is that these assets are a lot more fungible than you imply.

> It is not a good measure of the money someone may be able to realise.

And as such, when you get into the higher ranges, net worth is quite a good indicator.

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