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, New York’s Proposed Mark-to-Market Tax Decouples From Federal Tax. 99 Tax Notes State 794 (2/22/21); 170 Tax Notes Federal 1243 (2/22/21), Saint Louis University School of Law Legal Studies Research Paper Series, 2021-05, Also available http://dx.doi.org/10.2139/ssrn.3775207