No, I'm not defending them. I think billionaires behaving like this is garbage behavior, I personally think that if I were a billionaire I would not behave like this (and if any multi-billionaires out there are willing to fund it, I would happily consent to the experiment :D)

What I'm saying is that the specific things that this article are claiming should be taxable income, would not meaningfully impact billionaires - they can afford a much higher baseline cost to move to a different shelter.

But any law that attempted this kind of loans against assets that have increased in value, would disproportionately impact non billionaires. Because it would hit standard loan types used by ordinary people. It would hit people had created there own business that was successful, but not a billion $ multinational.

The billionaires meanwhile would be continuing to travel in their tax deductible private jets, while paying negligible tax on their explicit "real" earnings via a relentless stream of tax avoidance scams and tax cuts specifically reducing the tax of the already ultra wealthy.

Targeting something like loans against assets that have increased in value is a BS bandaid that literally falls off in the next tax cycle once their accountants work out a new trick.

The actual fix is real corporate tax rates, non regressive individual taxes (in most countries the % of your annual income only that goes to taxes tends towards the maximum tax rate as you income increases. In the US there comes a point where your tax rates start going down again. You still pay more than others in absolute terms but the % decreases).

Increasing corporate taxes also impacts the absurd wealth growth of billionaires, because a corporation can manufacture an increase in value in owner's stock by taking the excess cash they have due to low tax rates, and just buying back shares - effectively paying the various funds and billionaires without ever actually transferring any assets to them at all so there's not even rudimentary income tax. Increasing tax rates also means the relative value of cost cutting, deferred maintenance, etc decreases - a lot of modern US corporate behavior basically originates from the "fuck you I'm already rich" tax cuts of the 80s, which had the overwhelming impact of rewarding cost cutting over actual development, wealth transfer over wages, etc (Obviously this is a "complex issue", yada yada, but that's the fairly well documented impact of Reagan/trickle down economics).

So don't come at me like I'm defending billionaires just because I'm saying patching individual tax avoidance scams is not a solution, recognize that shit like this is not fixed by patching around the edges. America now has a tonne of billionaires, created/funded by shitty corporate liability law, massive tax cuts for decades, and generally garbage enforcement of what minimal tax evasion laws exist. Those billionaires have got there's and it not possible to undo that for them - the law is pretty clear on not being able to retroactively change tax polices. Any effective changes are going to be at the start of the trust fund baby->billionaire pipeline, and that means boring corporate and individual tax law changes and increases. Again, not band aids for whatever this years most popular tax-avoidance-for-billionaires scheme is.