If the problem is billionaires borrowing against unrealized gains, then just require taxes to be paid on unrealized gains when someone uses it as collateral for borrowing. It’s a financial txn that’s identified easily and reported - the assets are even valued at that point.
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Problem is everything you have is always implicitly collateral for everything you buy on credit of any form. It’s not just billionaires. It’s college students buying burritos. Also, it’s not always 1:1 and loans could be massively over collateralized.
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Everyone with a HELOC would need to reassess the value and pay taxes on the unrealized gain/loss of their home every time they utilize the credit line?
There are loopholes for billionaires. Ownership structures, committing to not take on debt outside of your $1b loan.

