taxation, state taxation, realization, recognition, revenue enhancement
A proposal decouples NY from federal tax computations to tax billionaires on unrealized appreciation. If enacted, the proposal generates basis discontinuities across borders but enhances state revenue and may prove attractive to many states. The article reviews how states seek to enhance revenues and considers issues of cross-border taxation and the fundamental right to travel.
Ordower, Henry, Decoupling State Income Tax from Federal: Current Taxation of Unrealized Gain, the New York Proposal (January 28, 2021). Saint Louis U. Legal Studies Research Paper Forthcoming, Tax Notes Federal, Tax Notes State.