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ARGUMENTS AGAINST TAXING UNREALIZED CAPITAL GAINS OF VERY WEALTHY
FALL FLAT  
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Chuck Marr, Samantha Jacoby
September 11, 2024
Center on Budget and Policy Priorities
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*
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*
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*
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_ Middle Class Often Taxed on Unrealized Capital Gains _

Long term Capital Gains Highly Concentrated, Center on Budget and
Policy Priorities

 

A proposal in the Biden-Harris Administration’s 2025 budget[1]
[[link removed]] would
require households with more than $100 million in wealth to pay income
taxes of at least 25 percent of their annual income, including their
unrealized capital gains — gains in the value of assets that they
have not yet sold. Critics argue that unrealized capital gains, which
are a primary source of income for many extremely wealthy households,
are mere “paper” gains that do not constitute real income (though
they meet a textbook definition of income).[2]
[[link removed]] But
unrealized gains make asset owners better off in very real ways.
Claiming that unrealized gains are not “real” is akin to claiming
that individuals such as Jeff Bezos and Elon Musk are not rich unless
they sell their companies’ stock.

Claiming that unrealized gains are not “real” is akin to claiming
that individuals such as Jeff Bezos and Elon Musk are not rich unless
they sell their companies’ stock.
[[link removed].]

Critics also claim the proposal would mark a radical departure from
current tax practices, but this too is incorrect. Two of the main
types of assets that middle-income households own — their homes and
defined-contribution retirement accounts like 401(k)s — are already
taxed in ways that resemble proposals to tax the unrealized capital
gains of the very wealthy. A family’s property taxes typically rise
as the value of their home rises, and middle-class people pay the tax
year after year in amounts reflecting those gains without selling
their homes. Retirement account holders are required to begin
realizing their deferred gains in those accounts and pay the
associated tax when they reach a certain age, and their heirs then pay
tax on any remaining gains.

Homes and retirement accounts account for relatively small shares of
the income and wealth of very wealthy households, who tend to directly
own large amounts of corporate stock or other capital assets. These
assets face no comparable required realization requirement or annual
tax. Instead they often increase in value, tax-free, year after year,
and if they are never sold, the income tax that would be owed on those
gains is simply _erased_ when their heirs inherit them.

Requiring very wealthy people to pay income taxes on their unrealized
gains and ending their ability to permanently avoid income tax when
they pass appreciated assets to their heirs would thus constitute a
reasonable reform. It would make the tax code more equitable while
raising $500 billion in revenue over ten years, according to the
Treasury Department,[3]
[[link removed]] from
a small subset of the wealthiest households in the country.

Substantial Income of Very Wealthy Households Escapes Annual Tax

The individual income tax is our main federal tax, accounting for
roughly half of federal revenue. For households along most of the
income spectrum, the progressive federal income tax generally works as
it should, with higher-income households paying a larger share of
their incomes in tax than households with lower incomes. But this
relationship often breaks down at the very top. That’s because very
wealthy households accumulate a very large share of capital gains
(increases in the value of stocks, bonds, real estate, or other
assets), which enjoy two important tax advantages: deferral of
unrealized capital gains and stepped-up basis.[4]
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FIGURE 1

DEFERRAL OF CAPITAL GAINS INCOME. Households that accumulate capital
gains don’t have to pay tax on those gains until, or unless, they
“realize”_ _these_ _gains, usually by selling the asset. This
ability to put off paying capital gains tax is known as
“deferral.” Deferral overwhelmingly benefits wealthy households
because they own the overwhelming share of capital gains: nearly 70
percent of _realized_ capital gains go to the top 1 percent of
taxpayers.[5]
[[link removed]] (See
Figure 1.)

The distribution of _unrealized _gains is also highly skewed toward
the very wealthy. Because of deferral, wealthy households only report
a small share of their total capital income on their tax returns.[6]
[[link removed]] Unrealized
gains aren’t taxed, so filers don’t have to report them.

Research shows that unrealized gains constitute a growing share of a
household’s total income as one moves up the wealth scale.[7]
[[link removed]] In
2021, for example, the _Washington Post_ noted that “the wealth of
nine of the country’s top [tech industry] titans has increased by
more than $360 billion in the past year,” and nearly all of the
increase was due to the rising value of their holdings of their
companies’ stock.[8]
[[link removed]] Without
policy changes, much of this wealth increase might _never_ appear on
income tax returns.

STEPPED-UP BASIS. Under a tax code provision known as “stepped-up
basis,” the income tax that a wealthy person would have owed on an
asset’s increase in value since they purchased it is erased when
they die and pass their appreciated asset to their heirs. Neither they
nor their heirs owe any income tax on this increase. (Technically, the
asset’s basis — or the price paid for it — is “stepped up”
to its fair market value at the time of inheritance.) Stepped-up basis
encourages wealthy people to turn as much of their income into capital
gains as possible and hold assets until their death, when a lifetime
of gains becomes _permanently_ exempt from income tax.[9]
[[link removed]]

Together, deferral and stepped-up basis enable some of the country’s
wealthiest people to go through life without paying income taxes on
much or all of their income each year, or ever. Among other impacts,
this worsens inequality in income and wealth, both overall and across
racial and ethnic groups. Because of racial barriers to economic
opportunity, households of color are overrepresented at the lower end
of the income and wealth distributions, while white households are
overrepresented among the wealthy. For example, the wealthiest 10
percent of white households — a group that makes up just 7 percent
of households — holds 61 percent of the nation’s wealth. By
contrast, people of color account for 33 percent of all households but
just 14 percent of the nation’s wealth. (See Figure 2.)

Figure 2

Policymakers can change the tax code in several ways to treat some or
all of the unrealized capital gains of the wealthiest households as
taxable income. One is to make the gains taxable each year, as in
Senate Finance Committee Chairman Ron Wyden’s proposal to shift to a
“mark-to-market” system for taxing capital gains.[10]
[[link removed]] A
much more modest approach would be to repeal stepped-up basis: while
wealthy people could still avoid tax on unrealized capital gains
throughout their lives, they would have to pay taxes on those deferred
capital gains at death. A third option, which the Biden-Harris
Administration has proposed, would combine elements of both by
essentially requiring very wealthy households to _prepay_ some of
their taxes on unrealized capital gains each year — similar to the
withholding system that applies to wages and salaries — and paying
any remainder when those gains are realized.

Biden-Harris Proposal Would Eliminate This Tax-Free Treatment

The Biden-Harris Administration’s 2025 budget would establish a
minimum tax on total income, including unrealized capital gains, for
the 0.01 percent of households with at least $100 million in assets
— the tax would phase in and apply fully to households with at least
$200 million in wealth.[11]
[[link removed]] The
proposal would also end the stepped-up basis loophole for wealthy
households with significant unrealized gains: married couples with at
least $10 million in unrealized capital gains or single filers with at
last $5 million in capital gains.[12]
[[link removed]]

The proposal’s critics argue that unrealized gains do not constitute
“real” income because the asset owner has not received cash in
exchange for the asset, whose value can either rise or fall before the
asset is sold. For example, a Heritage Foundation economist recently
argued that “until an asset is actually sold, any increase in value
is purely speculative. It isn’t real, hence the classification of
unrealized.”[13]
[[link removed]] But
this argument ignores the fact that the wealthy receive significant
new value — or income — from their assets even before they sell.
Unrealized gains make asset owners better off in very real ways: stock
purchased 20 years ago for $20 million that’s now worth $100 million
has the same value as $100 million of stock purchased today (that has
no unrealized gains yet).

As Martin Sullivan, chief economist at Tax Analysts, has explained,
“[U]nrealized gain is economic income. Unrealized does not mean
unreal. The wealthy can see it very clearly on their brokerage
statements, even if the IRS will not see it on tax returns.”[14]
[[link removed]]

In addition to watching their untaxed income grow, wealthy households
can _use_ this income to finance their (often lavish) lifestyles.
“It is a simple fact that billionaires in America can live very
extraordinarily well completely tax-free off their wealth,” law
professor Edward J. McCaffery writes.[15]
[[link removed]] They
can do so by borrowing large sums against their unrealized capital
gains, without generating taxable income.

For example, Larry Ellison, Oracle’s chief executive officer and one
of the world’s richest people, has pledged over 300 million shares
of Oracle stock worth over $45 billion as collateral for a personal
credit line.[16]
[[link removed]] This
lets him obtain cash without selling shares; thus, he avoids paying
taxes, and the stock can continue growing in value. Though he must pay
interest on the debt and he or his heirs will eventually pay back
amounts borrowed (e.g., using the proceeds of appreciated assets that
were never subject to the income tax), this is often a much cheaper
strategy than selling stock and paying capital gains taxes. As a
recent article by two tax scholars observes, “Ellison hasn’t just
gotten richer on paper when he borrows against his stock to buy a
Hawaiian island; he’s used that income just as if he’d sold the
stock.”[17]
[[link removed]]

This doesn’t mean that the gains _only _become income when they
are leveraged to finance other investments or consumption. Quite to
the contrary: the gains were always _real _income available to the
filer to use to buy Hawaiian islands, yachts, or invest in other types
of stock or business investments. The gains raise their purchasing
power, making them better off, whether or not they use that purchasing
power to actually purchase things.

Middle-Class People Often Taxed on Unrealized Gains or Required to
Realize Gains

Critics of proposals to tax unrealized gains of wealthy people fail to
acknowledge that two of the primary assets owned by _non_-wealthy
people — their homes and defined-contribution retirement accounts
like 401(k)s — are_ already_ taxed in ways that resemble the
capital gains proposals. To be sure, there are important differences
between the taxation of these types of assets and capital assets like
directly held corporate stock; for example, property taxes are not
income taxes and are applied by state and local governments, not the
federal government.[18]
[[link removed]] But
as explained below, the reality is that in certain long-standing and
uncontroversial contexts, asset owners pay tax as their assets gain
value over time or are required to realize gains at a certain age.
This fact contradicts critics’ claim that taxing unrealized capital
gains would be novel or untested.

Property Taxes Apply to Unrealized Gains From Increases in Home Values

Corporate stocks and privately held businesses are the largest
appreciable assets for the wealthiest people, but for the middle
class, the biggest asset by far is their home.[19]
[[link removed]] These
homes are subject to annual state and local property taxes across the
country. The methods of assessing property values and calculating
taxes differ, but generally the tax is calculated by multiplying the
assessed value of the property (minus any exemptions) by the local
property tax rate.[20]
[[link removed]] When
a family buys a house, the property’s initial assessed value may be
based on the purchase price of the house, and jurisdictions typically
reassess the home’s value (based on what the house would sell for in
a third-party transaction, for example) at specified intervals. As
officials from the state of Illinois explained in a recent Q & A for
residents:

Your property’s value is determined by many factors. Your assessment
can increase because your neighborhood is improving, the sales prices
of homes in your area are increasing, and inflation. The value that
the assessor assigns to your property is the amount that the assessor
determines your property would sell for in today’s market.[21]
[[link removed]]

In a recent example from the end of last year, the state of Maryland
announced that assessments for a segment of properties would rise 23.4
percent from the last assessment three years prior.[22]
[[link removed]]

A home’s assessed value often increases over time due to market
factors, and if it does, the property tax is partially a tax on the
home’s increase in value, or an unrealized gain. This is the case
even though no sale has occurred, and no cash has flowed to the
homeowner. Yet the taxation of the portion of a property’s value
that represents unrealized gains is a relatively uncontroversial
aspect of a tax that accounts for over 15 percent of state and local
general revenue, helping to fund public schools, for example.[23]
[[link removed]]

If middle-income homeowners can pay taxes that in part reflect the
increase in value of their primary asset, very wealthy households can
pay income tax on the increase in value of_ their _primary assets:
corporate stocks.

Retirement Account Holders Must Pay Income Tax on Accrued Gains

Middle-class families who own corporate stocks typically do so within
retirement accounts such as 401(k) accounts, rather than in private
brokerage accounts. Families between the 60th and 80th income
percentiles have 28 percent of their assets in retirement accounts but
only 12 percent in directly held corporate stock.[24]
[[link removed]] The
situation is reversed for the top 1 percent of families: only 5
percent of their assets are in retirement accounts, versus 44 percent
in corporate stocks.[25]
[[link removed]]

Under a typical 401(k), a person sets aside an average of about $5,000
per year from their paychecks on a pre-tax basis.[26]
[[link removed]] The
underlying assets typically increase in value over time, and account
holders do not pay tax each year on their gains. Thus, owners of
retirement accounts, like direct owners of corporate stock, enjoy the
benefit of deferral: their annual unrealized gains are not counted
annually as taxable income. But the similarity in the tax treatment of
directly held corporate stock and retirement accounts ends later in
life.

Starting at age 73,[27]
[[link removed]] retirement
account holders must take mandatory distributions — about $4,000
annually for every $100,000 in account balance (increasing with the
age of the holder) — in part so they can’t use their accounts as
tax shelters. This begins the process of drawing down the accounts and
effectively requires account holders to begin realizing their gains,
even if they would not otherwise want to. The distributions flowing
out of the accounts, including the original contributions plus the
accrued gains, are taxed at ordinary income tax rates.[28]
[[link removed]]

Moreover, if a retirement account holder dies with an account balance
and leaves it to a family member or other heir other than a
spouse,[29]
[[link removed]] the
heir must liquidate the account over a ten-year period. The heir also
must pay individual income taxes at ordinary income tax rates on the
distributions in each of those ten years.

The bottom line for middle-class people who hold stocks in retirement
accounts is that, while they enjoy generous tax advantages during
their working lives as they build up their accounts, all accrued
unrealized capital gains must be realized by either the account holder
starting at age 73 or by their heirs within ten years of receiving
them. Also, their capital gains income is taxed at ordinary income tax
rates, rather than the lower capital gains rate enjoyed by holders of
corporate stock held outside of retirement accounts. Turning 73 thus
has important tax consequences for middle-class retirement account
holders.

In contrast, for wealthy people whose assets consist primarily of
direct ownership of stock or other capital assets, 73 is just another
birthday. They face no realization requirement for capital gains
accrued over a lifetime of owning corporate stock. By the end of their
lives, they could have millions, hundreds of millions, or even
billions of dollars in unrealized capital gains from their privately
held stocks or other assets — income that has never faced the income
tax. And after they die, the entire income tax liability on those
gains is simply erased, for them and their heirs.[30]
[[link removed]]

Minimum Tax Would Be Paid Over Time, Raise Significant Revenue

Some critics have claimed that the Biden-Harris proposal to tax
unrealized capital gains of extremely wealthy households would be
unworkable or require business owners to prematurely sell their
investments, such as shares in a closely held company, to pay the
tax.[31]
[[link removed]] The
proposal, however, includes several design mechanisms to make it
easier to administer.

For instance, the tax would be paid over several years — essentially
a down payment on the tax that will be owed when the gains are
realized (typically, when assets are sold).[32]
[[link removed]] Spreading
out the payments in this way would also mitigate concerns about
wealthy taxpayers who have large gains in one year and losses the
next: if a taxpayer later has a large unrealized loss, those losses
will also be spread out over several years and future tax payments
will be reduced to reflect the losses, with refunds paid to taxpayers
who have no minimum tax payments to offset. It would also mitigate
concerns that public company founders would have to sell large amounts
of stock to pay the tax, because their initial payments would be made
over nine years.[33]
[[link removed]]

Another design feature would allow taxpayers who primarily own
non-publicly traded assets — like shares of a closely held company
— to defer tax (with a charge akin to interest) until they sell
assets. Moreover, the proposal applies only to the approximately
10,000 U.S. taxpayers with $100 million in assets,[34]
[[link removed]] and
these very wealthy people tend to own large amounts of highly liquid
assets like publicly traded stock or other financial assets, not
shares in small businesses.

The proposal would raise $500 billion over ten years, according to the
Treasury Department,[35]
[[link removed]] generated
from a small subset of the wealthiest households in the country —
those with more than $100 million in assets — who today often enjoy
extremely low average tax rates. Thus, the proposal would not only
mark a step toward creating a fairer tax code but would also raise
revenue that is badly needed to meet the nation’s commitments to
seniors, make high-value investments that will improve well-being and
broaden prosperity, and improve the fiscal outlook.[36]
[[link removed]]

END NOTES

[1]
[[link removed]] Vice
President Harris’ campaign has endorsed this proposal in the
Administration’s budget. See Twitter post of Joseph Zeballos-Roig,
reporter for Semafor, September 4,
2024, [link removed].

[2]
[[link removed]] Income,
according to the textbook definition, is the sum of one’s
consumption and change in net worth. This is known as Haig-Simons or
economic income and includes both realized and unrealized capital
gains, because “whether you sell the asset does not matter because
an increase in the value of assets you own increases your
purchasing _power_.” Joel Slemrod and Jon Bakija, _Taxing
Ourselves: A Citizen’s Guide to the Debate Over Taxes,_ MIT Press,
2017.

[3]
[[link removed]] Department
of the Treasury, “General Explanations of the Administration’s
Fiscal Year 2025 Revenue Proposals,” March 11,
2024, [link removed].

[4]
[[link removed]] Capital
gains are also taxed at lower rates than ordinary income, topping out
at 23.8 percent for the highest earners (including a 3.8 percent net
investment income tax on high earners).

[5]
[[link removed]] Tax
Policy Center, “T23-0002 – Distribution of Long-Term Capital Gains
and Qualified Dividends by Expanded Cash Income Percentile,
2022,” [link removed].

[6]
[[link removed]] Jenny
Bourne _et al.,_ “More Than They Realize: The Income of the
Wealthy,” _National Tax Journal,_ June
2018, [link removed].

[7]
[[link removed]] _Ibid_.

[8]
[[link removed]] Nitasha
Tiku and Jay Greene, “The billionaire boom,” _Washington
Post, _March 12,
2021, [link removed].

[9]
[[link removed]] Leonard
E. Burman, “Biden Would Close Giant Capital Gains Loopholes—At
Least for the Rich,” Tax Policy Center, April 28,
2021, [link removed].

[10]
[[link removed]] While
serving as the Senate Finance Committee’s ranking Democrat in 2019,
Senator Wyden released a white paper calling for enacting a
mark-to-market system for capital gains and raising the capital gains
tax rate to the same rates as taxes on ordinary income. Senate Finance
Committee Democrats, “Treat Wealth Like
Wages,” [link removed].
Under Wyden’s proposal, large capital gains on corporate stock and
other securities that wealthy households own would be taxed annually,
while non-publicly traded assets would be subject to a deferral charge
at the time of sale.

[11]
[[link removed]] The
phase-in reduces a household’s minimum tax liability to the extent
that the liability is greater than two times the minimum tax rate
times the amount of the household’s wealth that exceeds $100
million.

[12]
[[link removed]] Separately,
the budget also proposes to end, for high-income households, the
special discounted tax rate that applies to capital gains. Candidate
Harris has endorsed raising the capital gains tax rate for households
with more than $1 million in income to 28 percent and the net
investment income tax rate for households with more than $400,000 in
income to 5 percent, for a combined 33 percent top tax rate on capital
gains. Brian Faler, “Harris goes her own way on capital gains tax
hike,” _Politico,_ September 4,
2024, [link removed].

[13]
[[link removed]] Alec
Schemmel, “‘Beyond Insane’: Economists slam Biden-Harris
proposal to tax unrealized investment returns,” Fox News, August 26,
2024, [link removed].

[14]
[[link removed]] Martin
Sullivan, “Do the Superrich Pay Tax at the Highest Rates?” _Tax
Notes,_ May 17, 2021.

[15]
[[link removed]] Edward
J. McCaffery, “The Death of the Income Tax (or, the Rise of
America’s Universal Wage Tax),” _Indiana Law Journal, _revised
April 10,
2019, [link removed].

[16]
[[link removed]] Oracle
Corp., Schedule 14A, September 22,
2023, [link removed].
As of September 10, 2024, Oracle stock is trading at a value of
$155.89. Bloomberg, “Markets Data, Oracle Corp,” August 29,
2024, [link removed].

[17]
[[link removed]] Edward
G. Fox and Zachary Liscow, “No More Tax-Free Lunch for Billionaires:
Closing the Borrowing Loophole,” _Tax Notes, _January 22,
2024, [link removed].
In 1992, Ellison bought 98 percent of the island of Lanai for $300
million.

[18]
[[link removed]] State
and local taxes, like property taxes, are not subject to the
constitutional restrictions on federal taxes like the federal income
tax. Furthermore, property taxes are generally imposed on the entire
assessed value of real property, not only the gain that has accrued
since a home’s purchase. The Biden-Harris proposal only applies to
gains, or income. It is also important to note that the tax
preferences for retirement savings are substantial and mainly benefit
people with higher incomes and financially secure retirements.

[19]
[[link removed]] John
Bailey Jones and Urvi Neelakantan, “Portfolios Across the U.S.
Wealth Distribution,” Federal Reserve Bank of Richmond, Economic
Brief No. 23-39, November
2023, [link removed]

[20]
[[link removed]] Annual
tax rates vary but tend to fall roughly between 0.25 percent and 2.0
percent. Jim Probasco and Mia Taylor, “Property tax rates by state:
What to expect in your area,” Bankrate, May 29,
2024, [link removed].

[21]
[[link removed]] State
of Illinois, “How can the value of property increase when I
haven’t made any changes to my
property?” [link removed].

[22]
[[link removed]] Maryland
Department of Assessments and Taxation, “Maryland Property Values
Rise 23.4% According to Maryland Department of Assessments and
Taxation’s 2024 Reassessment,” December 29,
2023, [link removed].

[23]
[[link removed]] Tax
Policy Center, “Briefing Book: How Do State and Local Property Taxes
Work?” [link removed].

[24]
[[link removed]] Board
of Governors of the Federal Reserve System, “DFA: Distributional
Financial Accounts,” June 14,
2021, [link removed].

[25]
[[link removed]] _Ibid_.

[26]
[[link removed]] This
discussion does not apply to Roth 401(k)s, under which employees
contribute after-tax amounts and capital gains, dividends, and
interest accrue tax-free; qualified withdrawals in retirement are also
tax-free.

[27]
[[link removed]] In
2022, the EARN Act raised the starting age for these required minimum
distributions from 72 to 73 for account holders who turn 73 before
2033, and to 75 for account holders who turn 73 thereafter. This
change benefits a small group of affluent people whose retirements are
financially secure without tapping their retirement accounts. See
Chuck Marr and Samantha Jacoby, “House Bill Would Further Skew
Benefits of Tax-Favored Retirement Accounts,” CBPP, April 29,
2022, [link removed].

[28]
[[link removed]] The
ability to defer tax on retirement contributions and earnings until
earnings are withdrawn is a substantial subsidy because there is no
tax on the growth in the account assets over time as they produce
earnings and because average tax rates tend to be lower in retirement,
when the tax is eventually paid. Tax subsidies for retirement savings
are one of the largest federal tax expenditures, costing around $380
billion annually. Michael Doran, “The Great American Retirement
Fraud,” October 28,
2022, [link removed].

[29]
[[link removed]] There
are additional limited exceptions to the ten-year liquidation rule for
minor children of the original account holder, people with
disabilities or chronic illnesses, or people who are less than ten
years younger than the original account holder.

[30]
[[link removed]] The
asset may be subject to the estate tax, which theoretically provides a
last opportunity to collect some tax on income that has escaped the
income tax. However, a decades-long political effort has eviscerated
the estate tax so much that Gary Cohn, then-director of President
Trump’s National Economic Council, reportedly told Senate Democrats
in 2017, “Only morons pay the estate tax.” Julie Hirschfeld Davis
and Kate Kelly, “Two Bankers Are Selling Trump’s Tax Plan. Is
Congress Buying?” _New York Times,_ August 28,
2017, [link removed].

[31]
[[link removed]] See
Schemmel, _op. cit_.

[32]
[[link removed]] Once
the minimum tax is imposed, households subject to it could make
prepayments over nine years for previously accrued gains and five
years for gains accrued after enactment.

[33]
[[link removed]] Jason
Furman, “Biden’s Better Plan to Tax the Rich,” _Wall Street
Journal_, March 28.
2022, [link removed].

[34]
[[link removed]] Robert
Frank, “The number of people with at least $100 million has doubled
since 2003,” CNBC, October 10,
2023, [link removed].

[35]
[[link removed]] Department
of the Treasury, _op. cit._

[36]
[[link removed]] Richard
Kogan _et al.,_ “More Revenue Is Required to Meet the Nation’s
Commitments, Needs, and Challenges,” CBPP, June 17,
2024, [link removed].

* Federal taxes
[[link removed]]
* Capital gains taxes
[[link removed]]
* Personal taxes
[[link removed]]
* Inequality
[[link removed]]
* wealth
[[link removed]]
* tax fairness
[[link removed]]

*
[[link removed]]
*
[[link removed]]
*
*
[[link removed]]

 

 

 

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