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Old 9th June 2021, 10:07 AM   #161
TragicMonkey
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Originally Posted by SuburbanTurkey View Post
Sure, but it's a tax on simply owning something of value, not realizing that value through sale. It is fairly straightforward to likewise tax the owning, and not just the liquidation, of other valuable things like stocks and other capital assets.
The difference is that no matter what happens to the value, you still have the house.

How would you tax unrealized gains?

1990 Ms Vivivacia LaButt buys 1 share of MonkeyCo at $20.
1991 MonkeyCo is worth $30. Ms LaButt pays X% of $10.
1992 MonkeyCo is worth $28. Ms LaButt pays...what? X% of $8? -X% of $2?
1993 MonkeyCo is worth $100. Ms LaButt pays X% of...which difference between numbers?
1994 MonkeyCo is worth $0. Ms LaButt...gets refund of all taxes paid on it since 1991? Or gets nothing, and having invested she is now out not just the original $20 but also the sum of all three years taxes she paid on the gains she didn't end up making?

The result would be to make investing even more of a gamble than it is, to the point where the risk would be unaccceptable in most cases. And every time someone did make a gain they'd be more inclined to immediately sell their holdings to actually get something out of it, than to hold it for future growth.

It would pretty much kill investing for most people and companies. Ironically the only people who would then be safe enough to do investing would be...the ultra wealthy. Because instead of investing most of their wealth they'd store it somewhere less risky, and only gamble what they could stand losing.

I get it, I really do: it sucks that some people are super duper wealthy and aren't paying enough tax. The solution isn't to burn down the concept of investment and make it impossibly difficult for everyone. The solution is to just bump up the unreasonably low rates currently being levelled. Tax capital gains at ordinary income levels is one frequent suggestion. If Ms LaButt makes a million a year from (sold) investments and I make a million a year as a swimsuit model we could both pay the same percentage of tax on those incomes. That seems infinitely fairer than crippling the nature of investments because some people are doing too well with it.
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Old 9th June 2021, 10:10 AM   #162
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Originally Posted by Bob001 View Post
So Jeff Bezos' Amazon stock and Elon Musk's Tesla stock have no value unless they sell them? Do you really wanna make that claim?
This is duplicating the other thread, see my posts in that one if you care to.
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Old 9th June 2021, 10:12 AM   #163
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What debt do our hypothetical billionaires owe to society on potential income?

Sure when they do sell it, tax the Brock Lesnar F5 out of them.
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Old 9th June 2021, 10:12 AM   #164
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Originally Posted by Bob001 View Post
One point of the story is that no capital gains are taxed until the asset is sold, which might be never, no matter how much it appreciates. And it's not just "paper wealth" if you can borrow against it, and invest the proceeds of the loans.
This has been a talked-about tax strategy of choice for the ultra-rich. Elon Musk goes to JP Morgan Chase, or some other bank, and takes a loan out against his stock.

The solution is to have a progressive consumption tax. One of the most common objections to a progressive income tax is that it "punishes" success ("success"), but any income tax punishes people for working, which is pretty silly. We do not want to disincentivize creating wealth. Consumption is the problem -- which involves taking resources from society.

A progressive consumption tax would also reconcile the different rates between labor and capital gains. Profligate heirs would have to pay more than sales taxes.

One of our better posters created a thread on the idea, but it was predictably ignored.
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Old 9th June 2021, 10:20 AM   #165
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Originally Posted by JoeMorgue View Post
Okay so property taxes.

I bought my house for 165,000 a few years ago.

It's worth (by all estimates) far more now, around 225,000.

What is the "fair" or "right" property tax I should have to pay? X percent of 165k or X percent of 225k?
Most states would calculate it on the assessed value, which is generally the current market value minus certain specific deductions and credits. My impression is that California froze its property taxes for current owners under Prop. 13, so two people owning identical houses next to each other can pay wildly different rates based on when the bought the properties.

So what's generally agreed as "fair" in most places starts with current value.
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Old 9th June 2021, 10:22 AM   #166
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Okay but the idea of taxes is that I owe some debt to society to pay for using its roads and Army and laws and all that.

What debt do I incure to society by having it unrealized value go up in price after I purchase it?

I buy a house. I pay taxes on the purchase, that makes perfect sense. Paying taxes on that initial purchase value every year even makes some sense. But my home value isn't exactly under my control. It's not my "fault" (not exactly the term since I'm not talking moral blame but you get my point) if my house is worth more, and it's not like I'm costing society anymore to live in house.
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Old 9th June 2021, 10:24 AM   #167
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Originally Posted by Cain View Post
This has been a talked-about tax strategy of choice for the ultra-rich. Elon Musk goes to JP Morgan Chase, or some other bank, and takes a loan out against his stock.

The solution is to have a progressive consumption tax. One of the most common objections to a progressive income tax is that it "punishes" success ("success"), but any income tax punishes people for working, which is pretty silly. We do not want to disincentivize creating wealth. Consumption is the problem -- which involves taking resources from society.
.....
But how much of their wealth do the wealthy actually spend? By all accounts, Warren Buffett lives quite modestly, and for a long time (and maybe now) Elon Musk didn't even own a house. Unless you treat investments as taxable consumption, a consumption tax won't capture much.
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Old 9th June 2021, 10:26 AM   #168
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Originally Posted by Cain View Post
This has been a talked-about tax strategy of choice for the ultra-rich. Elon Musk goes to JP Morgan Chase, or some other bank, and takes a loan out against his stock.
I assume that the bank would then have to pay tax (well, ought to be paying tax, I sure they find a way out of it) on the profits they'd making by charging interest on that loan.

Quote:
The solution is to have a progressive consumption tax. One of the most common objections to a progressive income tax is that it "punishes" success ("success"), but any income tax punishes people for working, which is pretty silly. We do not want to disincentivize creating wealth. Consumption is the problem -- which involves taking resources from society.

A progressive consumption tax would also reconcile the different rates between labor and capital gains. Profligate heirs would have to pay more than sales taxes.
Sounds alright to me. The frugal millionaire who leaves his millions invested isn't going to pay tax on them, but his spendthrift heir will. In the interval the benefit of those millions goes to the bodies in whom they have been invested.
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Old 9th June 2021, 10:34 AM   #169
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Originally Posted by Bob001 View Post
But how much of their wealth do the wealthy actually spend? By all accounts, Warren Buffett lives quite modestly, and for a long time (and maybe now) Elon Musk didn't even own a house. Unless you treat investments as taxable consumption, a consumption tax won't capture much.
A consumption tax is only supposed to capture consumption. If Mary-Kate owns fifty mansions, a thousand supercars, and a mega-yacht named The Saucy Sue for a grand total value of $50 kajillion, her consumption was all those properties. Her impact on the rest of is is the wear-and-tear on the roads and sea, the materials and energy consumed, all the burden of her having all that stuff. Her sister Ashley, however, dumped her own $50 kajillion into a Vanguard mutual fund (VBORE, for boring people) and lives in an abandoned van down by the river. What's Ashley's consumption costing society? The girl wears only found clothing and eats only the ducklings she catches in the river. Until and unless she sells those shares and makes some money off them, Ashley's tax would and should be lower than Mary-Kate's, under a consumption tax scheme.
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Old 9th June 2021, 11:24 AM   #170
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Originally Posted by Bob001 View Post
But how much of their wealth do the wealthy actually spend? By all accounts, Warren Buffett lives quite modestly, and for a long time (and maybe now) Elon Musk didn't even own a house. Unless you treat investments as taxable consumption, a consumption tax won't capture much.
Are we primarily talking about a tax code that is fair or captures a lot of revenue for the government?

Discussions about inequality usually involve income, and someone produces a stat showing where the poor have a tiny slice of the pie whereas the rich have a massive outsized piece. Then the conversation quickly turns to wealth and the figures are predictably even more lopsided. However, if we want to measure a person's standard of living, we have to look at consumption. Thankfully, these figures are not as lopsided, due in part to (federal) tax breaks/exemptions for the poor and government transfers/benefits.

TM's Olsen-twin analogy is as good as anything economist Robert Frank has said over the last thirty years to illustrate the fairness of a progressive consumption tax.

Originally Posted by TragicMonkey View Post
I assume that the bank would then have to pay tax (well, ought to be paying tax, I sure they find a way out of it) on the profits they'd making by charging interest on that loan.
I imagine the burden would fall on the recipient since it's a personal loan. Musk is notorious for living off such loans, and I'm curious to learn his interest rate and how much he borrows.
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Old 9th June 2021, 11:26 AM   #171
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We can't write task codes just for Musk and Bezos.
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Old 9th June 2021, 11:32 AM   #172
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Originally Posted by Bob001 View Post
What you are describing are specific provisions of the tax code that benefit the wealthy, and that were controversial even when they were established. They can be changed. And it's not just paper wealth if it can be borrowed against, effectively creating the benefits of a sale without actually selling it. There's plenty here to think about.
The benefit of a sale is not having to go into debt and put up collateral in case of a default. Borrowing against assets does not in any way create the benefits of a sale.
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Old 9th June 2021, 11:46 AM   #173
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Originally Posted by JoeMorgue View Post
We can't write task codes just for Musk and Bezos.
Why not? As we slide into a second gilded age, a smaller and smaller circle of ultra-wealthy individuals are controlling more and more of this nation's wealth. Seems like exactly the kind of people that public policy should be addressing.
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Old 9th June 2021, 12:40 PM   #174
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Originally Posted by SuburbanTurkey View Post
Why not? As we slide into a second gilded age, a smaller and smaller circle of ultra-wealthy individuals are controlling more and more of this nation's wealth. Seems like exactly the kind of people that public policy should be addressing.
It isn't the nation's wealth.
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Old 9th June 2021, 12:45 PM   #175
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Originally Posted by theprestige View Post
The benefit of a sale is not having to go into debt and put up collateral in case of a default. Borrowing against assets does not in any way create the benefits of a sale.
It allows you to spend the money without paying taxes. That's the benefit.
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Old 9th June 2021, 12:46 PM   #176
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Originally Posted by JoeMorgue View Post
Okay but the idea of taxes is that I owe some debt to society to pay for using its roads and Army and laws and all that.

What debt do I incure to society by having it unrealized value go up in price after I purchase it?

I buy a house. I pay taxes on the purchase, that makes perfect sense. Paying taxes on that initial purchase value every year even makes some sense. But my home value isn't exactly under my control. It's not my "fault" (not exactly the term since I'm not talking moral blame but you get my point) if my house is worth more, and it's not like I'm costing society anymore to live in house.
Surely you don't need to have the concept of inflation explained to you.
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Old 9th June 2021, 02:57 PM   #177
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Originally Posted by JoeMorgue View Post
We can't write task codes just for Musk and Bezos.
Yeah, just like how ultra-rich people cannot expressly include or uniquely exploit parts of the tax code. Oh, wait...
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Old 9th June 2021, 04:11 PM   #178
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Originally Posted by Bob001 View Post
It allows you to spend the money without paying taxes. That's the benefit.

But don't they have to pay back the loan?
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Old 9th June 2021, 06:34 PM   #179
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Originally Posted by Solitaire View Post
But don't they have to pay back the loan?
Yes, but the money you borrowed was obtained without the tax that would have accrued if you sold the asset. How that shakes out can vary a lot.

So in one scenario you sell the asset, pay the tax, and use the net proceeds for your purchase. When done, you have the purchase, no debt, and you have spent the "opportunity cost" of the asset. This is an advantage if you do not have sufficient other income to repay the amount you're using for the purchase. There is no risk.

In the other you borrow on the asset, make the purchase, and then pay back the value of the purchase plus interest. When done, you have the purchase, no debt, and the opportunity to use the asset again. This may be better if you have, or anticipate, the income to cover the loan but can't raise it all in a lump right away. There is a risk.

How much you benefit from this may depend not only on the quality of the asset and its original purchase price, but on the source of the income with which you pay back the loan. Loan interest is likely to be lower than gains tax, but you pay interest on the entirety of the amount, not just the portion that is capital gain. If you bought stock very cheaply and it's grown greatly, borrowing may be cheaper because your gain is high. If it's stayed pretty close to the purchase price, the tax on gain will be very small because your gain is low. You will likely have paid a higher tax rate on the money you use to pay off the loan (if you are not finagling things as rich people can anyway).
Additionally, if your collateral is an income producing asset like a stock that pays dividends, that income continues to be yours, not the lender's.

How willing you are to pay some price to keep a good and growing asset will depend partly on how much it has already gained, and partly on how hard it might be simply to sell it and replace it.

All this comes down also to what you're buying and why. If you borrow money to buy a fancy car, you're probably going to lose no matter what you do. If you borrow to start a lucrative business or to buy a great investment opportunity, etc., then, as Ben Franklin pointed out long ago, you're getting the benefit using someone else's money.

I think ultimately it could get very complicted, and there would probably not be much to gain by trying to modify how unsold assets are valued, if we concentrated instead on making progressive taxation more progressive and on doing away with some of the myriad ways that rich people use loopholes and just plain cheat.

e.t.a. and of course this is a simplistic view of the whole thing, and not likely to be very applicable to the kind of people who borrow and bargain in billions, with the help of corporate lawyers and accounting firms, depreciation and incentives and....blah blah blah. It's pretty likely whatever they do they'll squeeze more out of it than we could imagine.
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Old 9th June 2021, 06:52 PM   #180
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Originally Posted by Bob001 View Post
But it is there, and they can use it as collateral for loans, which they can spend on living expenses or other investments, and the interest on the loans is usually tax-deductible.
The highlighted is the outrageous part. Interest on personal loans should never be tax deductible.

Of course, this is just one of many tax loopholes that politicians have deliberately created for the wealthy.
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Old 9th June 2021, 06:52 PM   #181
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Originally Posted by Bob001 View Post
It allows you to spend the money without paying taxes. That's the benefit.
That's not a benefit of the sale, though. That's a benefit of already having paid taxes on the acquisition of the asset. Or having paid taxes on the revenue used to acquire the asset.

And of course the lender has already paid taxes on the funds they're lending you.

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Old 9th June 2021, 07:24 PM   #182
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Originally Posted by bruto View Post
So in one scenario you sell the asset, pay the tax, and use the net proceeds for your purchase. When done, you have the purchase, no debt, and you have spent the "opportunity cost" of the asset. This is an advantage if you do not have sufficient other income to repay the amount you're using for the purchase. There is no risk.

In the other you borrow on the asset, make the purchase, and then pay back the value of the purchase plus interest. When done, you have the purchase, no debt, and the opportunity to use the asset again. This may be better if you have, or anticipate, the income to cover the loan but can't raise it all in a lump right away. There is a risk.
Sorry, but your premise is faulty here. In Scenario B you have to wait a certain time, putting money into the loan to pay it back, something you totally ignore in Scenario A. If the person is to spend the same amount of time putting the money they would have paid back in Scenario B into a saving account in Scenario A, then they would still end up with an Investment that is the size of the original asset, plus whatever interest would have been paid on the loan. In fact, it might actually work in their favour to do so because, in the end, they might end up with more than the asset would have been worth had they borrowed against it rather than sold it. Functionally they are no better off if they sell, spend and then reinvest the money than they would be if they borrowed, spent, and then paid back the loan.
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Old 9th June 2021, 07:32 PM   #183
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Originally Posted by Bob001 View Post
What's new is that ProPublica has obtained detailed confidential information about how little tax the wealthiest people in the world pay.
Absent better information I'm taking issue with the terms "leaked" as used in the OP and "confidential" as you use it. Sometimes the information is already in the public sphere and the "news" is created through analysis. Though this doesn't sound all that new to me; Buffett copped to this decades ago.

A mainstream news outlet is going to avoid using stolen information if possible.

The government isn't entitled to keep all information secret. Probably legislative bodies get less "freedom of information" type oversight because they're the ones who make the laws and they can exempt themselves. But it's best, IMO, to work on the assumption that this data is properly public; unless good reason can be given for keeping it secret.
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Old 9th June 2021, 09:30 PM   #184
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When I worked for Lucent everyone was at one point given a load of shares as a reward for how well the company was doing. The US employees didn't have to pay tax on them, but because Lucent didn't fill in the right forms we in the UK did. We had the choice of paying tax on their current value, or waiting until we sold them and paying tax on their value then. The share price was rising steeply at the time, so like many others I foolishly opted for the former. Those "free" shares ended up costing me thousands of pounds.
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Old 9th June 2021, 10:23 PM   #185
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Originally Posted by Minoosh View Post
The government isn't entitled to keep all information secret. Probably legislative bodies get less "freedom of information" type oversight because they're the ones who make the laws and they can exempt themselves. But it's best, IMO, to work on the assumption that this data is properly public; unless good reason can be given for keeping it secret.
I think that here you might have individual privacy issues too. Just because an individual is forced to share their information with the Government should not make that information public. The Government has collected it for a specific reason, to determine your tax liability, and, at least here in NZ, releasing that information to the general public would be a breach of privacy laws. Now I know that US privacy laws are different, but I wouldn't be surprised if there were some form of privacy laws around private citizens' tax returns remaining confidential.
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Old 9th June 2021, 11:18 PM   #186
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Originally Posted by Pixel42 View Post
When I worked for Lucent everyone was at one point given a load of shares as a reward for how well the company was doing. The US employees didn't have to pay tax on them, but because Lucent didn't fill in the right forms we in the UK did. We had the choice of paying tax on their current value, or waiting until we sold them and paying tax on their value then. The share price was rising steeply at the time, so like many others I foolishly opted for the former. Those "free" shares ended up costing me thousands of pounds.
Those shares ARE income so it is not unreasonable to expect that you would have to pay tax on them. If you sell the shares for more than they were worth when you got them then you might still be up for capital gains tax.
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Old 10th June 2021, 01:42 AM   #187
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Originally Posted by TragicMonkey View Post
How would you tax unrealized gains?
Strangely enough, my company is taxed on unrealised gains. The company had some extra cash and so we invested it in a mutual fund. Every year we value the asset and the gain/loss is treated as income for tax purposes.
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Old 10th June 2021, 01:53 AM   #188
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Originally Posted by psionl0 View Post
Those shares ARE income so it is not unreasonable to expect that you would have to pay tax on them. If you sell the shares for more than they were worth when you got them then you might still be up for capital gains tax.
That's the way it worked for me. I was given some share options when I joined a company. When these became actual shares I didn't have to pay any tax. When the company was sold I received around half the value in cash, half in shares in the purchasing company.

I paid capital gains tax on the cash on the difference in price I paid for the shares (zero) and what they sold for. After my tax free capital gains allowance was taken into account, it was around £40k in taxes - the remaining cash paid off the mortgage on our flat in Bristol.

I still have the shares in the other company. At one point they were worth close to zero but would now attract capital gains should they be sold all at once.
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Old 10th June 2021, 02:02 AM   #189
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Originally Posted by psionl0 View Post
Those shares ARE income so it is not unreasonable to expect that you would have to pay tax on them. If you sell the shares for more than they were worth when you got them then you might still be up for capital gains tax.
As I said, as it turned out they weren't income. They were worth virtually nothing when I finally got rid of them, I paid thousands of pounds of tax in anticipation of income I never received.

I accept it was my own fault, I was greedy. I gambled that the share price would go up at least a little more before I eventually sold them, so I would pay less tax by paying it early. I never expected the share price to drop through the floor. I ended up paying thousands more in tax than I actually received when I sold them.
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Old 10th June 2021, 02:11 AM   #190
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Originally Posted by Pixel42 View Post
As I said, as it turned out they weren't income. They were worth virtually nothing when I finally got rid of them, I paid thousands of pounds of tax in anticipation of income I never received.

I accept it was my own fault, I was greedy. I gambled that the share price would go up at least a little more before I eventually sold them, so I would pay less tax by paying it early. I never expected the share price to drop through the floor. I ended up paying thousands more in tax than I actually received when I sold them.
You weren't entitled to claim a capital loss when you sold the shares? That sucks.
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Old 10th June 2021, 02:19 AM   #191
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Originally Posted by psionl0 View Post
You weren't entitled to claim a capital loss when you sold the shares?
Not as far as I know, no. But, as is probably clear, I don't know much about such things.
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Old 10th June 2021, 02:54 AM   #192
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Originally Posted by Pixel42 View Post
Not as far as I know, no. But, as is probably clear, I don't know much about such things.
I remember when the ATO used to have a hotline that you could call if you had any questions like these and somebody would speak to you in peson.

Now that it has all been interneticized, you type in a question and get referred to a number of documents that tell you anything except the answer to the question you asked.
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Old 10th June 2021, 03:14 AM   #193
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A quick goggle tells me capital losses have to be declared within four years, and they can be offset against capital gains over several years. As (a) this was over 15 years ago and (b) I've never had any taxable capital gains in my life, being a (retired) working stiff rather than a wheeler dealer, I think I'll just have to grin and bear it.
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Old 10th June 2021, 03:24 AM   #194
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Originally Posted by Pixel42 View Post
A quick goggle tells me capital losses have to be declared within four years, and they can be offset against capital gains over several years. As (a) this was over 15 years ago and (b) I've never had any taxable capital gains in my life, being a (retired) working stiff rather than a wheeler dealer, I think I'll just have to grin and bear it.
The irony is that the capital gains tax rate is usually less than the income tax rate. It's a pity that you didn't have an advisor who would almost certainly have recommended Don's way.
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Old 10th June 2021, 03:36 AM   #195
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Originally Posted by psionl0 View Post
The irony is that the capital gains tax rate is usually less than the income tax rate.

It's a pity that you didn't have an advisor who would almost certainly have recommended Don's way.
It also means that you have to realise a capital gain to pay anything.

In any case, capital gains would still have been payable on the difference in value on which Pixel42 paid income tax and the price for which they were sold.
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Old 10th June 2021, 06:24 AM   #196
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Originally Posted by The Don View Post
It also means that you have to realise a capital gain to pay anything.
No you don't. You take out a loan on the assets and use that money. Then you either default on the loan (losing less than you'd pay in taxes, and the bank gets to write that off their taxes as well) or pay it with income you're already going to be taxed on, deducting the interest from your other taxes.

[ETA] Oh wait, you're describing a sane system, nevermind.

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Old 10th June 2021, 07:07 AM   #197
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Originally Posted by PhantomWolf View Post
Sorry, but your premise is faulty here. In Scenario B you have to wait a certain time, putting money into the loan to pay it back, something you totally ignore in Scenario A. If the person is to spend the same amount of time putting the money they would have paid back in Scenario B into a saving account in Scenario A, then they would still end up with an Investment that is the size of the original asset, plus whatever interest would have been paid on the loan. In fact, it might actually work in their favour to do so because, in the end, they might end up with more than the asset would have been worth had they borrowed against it rather than sold it. Functionally they are no better off if they sell, spend and then reinvest the money than they would be if they borrowed, spent, and then paid back the loan.
Yes, you are right, at least as far as we normal people are concerned, without digging too far into the tax issues, and it's my mistake not to mention this, as it's always been a sore point when people try to convince you that you should take out, for example, a car loan, instead of spending savings. The difference is actually a good deal worse than you suggest, because in the case of a time-payment loan, the compounding of interest is in reverse, so to speak, and early payments include almost no principal. Spending money you have and replacing it at the payment schedule results in principal replacement much sooner.

But I think the model changes when we're talking about rich people borrowing on assets and paying back with what may well be excess income from unknown sources, and I think it does depend on what you're putting up and how you're paying, and whether you have the income to service the loan in the first place.

To pick one example, I have some stock that came to me through a trust long long ago, which my grandfather acquired in 1917. It's appreciated and split many times since then, such that the cost basis is essentially zero. I could, of course, sell it, but the entire thing would be capital gain. I might well be better off using it as collateral for a loan which is not paid off piecemeal. The disproportionate payment of interest is not such an issue when you're not paying on time. My income would be the same, and it would include the income from the stock in question, which in this case comes close in rate of return to the interest rate on the loan. I could, in this case, probably borrow the money, spend the amount of the loan, and simultaneously sock the equivalent of monthly payments into savings, paying back the loan at the end. Whether this ends up as a net saving depends mainly on what tax I pay on the income I'm saving. In my case it probably would still not make sense, since I actually do pay taxes, but if I depend on the income from the stock, it might, and it very well might if I'm some filthy rich dude with offshore tax shelters and slick accountants.
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Old 10th June 2021, 07:24 AM   #198
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Personally I think rich people pay for more taxes than their fair share. A fair share would be to take the total budget of the government and divide by the number of citizens and send them a bill. The current progressive tax system is simply outrageous theft.
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Old 10th June 2021, 07:34 AM   #199
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Originally Posted by NewtonTrino View Post
A fair share would be to take the total budget of the government and divide by the number of citizens and send them a bill. The current progressive tax system is simply outrageous theft.
That would be something in the ballpark of at least 20,000 grand a year per person. That's very few people that's a reasonable amount to pay a year.
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Old 10th June 2021, 09:38 AM   #200
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Originally Posted by NewtonTrino View Post
Personally I think rich people pay for more taxes than their fair share. A fair share would be to take the total budget of the government and divide by the number of citizens and send them a bill. The current progressive tax system is simply outrageous theft.
That's a head tax. I like the idea because it puts people in their place, especially orphans.
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