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Andy Grewal (Iowa; Google Scholar), Billionaire Taxes and the Structure, 57 Ga. L. Rev. ___ (2023):

The US now has ten occasions as many billionaires because it had only a few many years in the past. This ever-growing class has sparked congressional curiosity in “billionaire tax” proposals. These proposals would typically require that billionaires acknowledge earnings when their asset values enhance, even when they haven’t bought their property.

Below present doctrine, billionaire taxes possible violate the belief requirement embedded within the Sixteenth Modification of the Structure. Nevertheless, this Article argues that present Sixteenth Modification doctrine suffers from deep infirmities and theoretical inconsistencies. With the conceptually sound interpretive method superior on this Article, a billionaire tax would move constitutional muster.

https://taxprof.typepad.com/taxprof_blog/2023/06/grewal-billionaire-taxes-and-the-constitution.html