“If men were angels,” James Madison wrote in Federalist 51, “no government would be necessary.” Similarly, if men were angels, we wouldn’t have to tax unrealized capital gains. It’s really awkward to tax an increase in the value of an investment that has not been cashed out. Doing so removes capital from the economy, and, if the value of the investment later falls, the justification for the tax may vanish. Also, a rise in an investment’s value doesn’t (usually) enable consumption the way cash income does. Given the choice between taxing unrealized income and taxing cash income, taxing cash income is almost always going to be better.But men (and women) are not angels, especially rich men and
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