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"Unrealized" throws people off when it comes to capital gains. If you bought $10,000 worth of a stock and it goes to $1 million, you're a lot wealthier, even if you haven't actually liquidated it yet. The gains may be tricky when it comes to taxes, but they're still real.

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Deliverability of $ is an issue, especially with private companies, given lack of liquid assets

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No question. And this may be a good reason to not have something that resembles a capital gains tax, due to liquidity, establishing true fair value, and a host of other things. But I think there are two separate questions.