KluwerLawOnline.com - Intertax

Debate: Capital Punishment Why a Wealth Tax Won’t Work, and What to Do Instead [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

This paper argues that an annual wealth tax is poorly matched to the goals most often invoked by its proponents – reducing inequality, protecting democracy, and strengthening social trust. The paper develops three difficulties that make an annual wealth tax an ineffective or counterproductive instrument: a valuation problem that cannot be solved by administrative refinement; a mismatch between ambitious democratic and social ends and modest fiscal means; and incentive effects that discourage saving, investment, and entrepreneurship. As an alternative, it proposes reforms within the income-tax base that target economic rents – the excess returns that fund durable political influence and reflect unfair, policy-created scarcities. Two design changes are emphasized: treating death as a realization event to reach decades of accrued gains and adopting a minimum tax on accrued gains for the ultra-wealthy, with mark-to-market for liquid assets and deferral with interest for others. Together these reforms better align means with ends, addressing both fairness and democracy without the knowledge and incentive costs of a wealth tax.

Volume 54 Online ISSN 0165-2826

Debate: Belling the Cat? A Response to Gabriel Zucman’s Billionaire Minimum Tax Proposal [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Gabriel Zucman’s global billionaire minimum tax proposal has significant merit in the realm of ideas to place in the progressive tax policy tool chest. While, if I were the global tax policy czar, I might change it in various ways, I would nonetheless support its adoption as is, relative to the alternative of simply doing nothing about the rise of extreme high-end inequality. If, in the end, it fails to offer a politically promising path forward, as I fear that it does, the fault lies not with its proponent, but with the political realities of our troubled times.

Volume 54 Online ISSN 0165-2826

Debate: Taxing Wealth or Taxing the Wealthy? Some Remarks on the Zucman Billionaire Tax [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Economist Gabriel Zucman presented ‘A Blueprint for a Coordinated Minimum Effective Taxation Standard for Ultra-High-Net-Worth Individuals’ (Gabriel Zucman, A Blueprint for a Coordinated Minimum Effective Taxation Standard for Ultra-High-Net-Worth Individuals, EU Tax Observatory (2024); this proposal further develops a number of articles authored by Zucman and several coauthors e.g., Emmanuel Saez & Gabriel Zucman, Progressive Wealth Taxation, Brookings Papers Econ. Activity 437–511 (2019); Emmanuel Saez & Gabriel Zucman, Wealth Taxation: Lessons from History and Recent Developments, 112 Am. Econ. Ass’n: P&P 58–62 (2022); Thomas Piketty, Emmanuel Saez & Gabriel Zucman, Rethinking Capital and Wealth Taxation, 39 Oxford Rev. Econ. Pol’y 575–591 (2023)) at the G20 meeting in Rio de Janeiro in June 2024. This Billionaire Tax proposal – of which Zucman provides a brief summary in this issue of INTERTAX (Gabriel Zucman, The Billionaire Tax: a (modest) proposal for the 21st century, INTERTAX (2025)) – has been met with wide political and scholarly interest. In this short comment, the author will not address the political debate on wealth and income inequality or dwell on the practical implications of global wealth taxation in general, i.e., on matters of administrability, compliance, and anti-avoidance tools. Rather, this article examines the role of the Zucman tax in the context of mainstream (individual and corporate) income taxation and highlights the underlying tension between taxing wealth and taxing wealthy individuals’ income.

Volume 54 Online ISSN 0165-2826

Debate: The Global Wealth Tax And Developing Countries [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

The growing international consensus on the need to tax ‘global billionaires’ in a socially acceptable manner has centred on a potential minimum tax on the consolidated wealth of these Ultra High Net Worth Individuals (UHNWIs). Such an initiative could both compensate for the practical difficulties of effective income (and capital gains) taxation at the national level due to financial mobility; and generate new fiscal resources for public goods such as health, education and environment. However, the implications for the ‘global south’ are still unclear and deserve further analysis. This article addresses three fundamental issues: the allocation of taxing rights, cooperation between tax authorities and the process of international fiscal negotiation. All three require clarification as to an appropriate common position for developing countries and we present concrete proposals for how to make progress on all three. The recently launched initiative on ‘Enforcing Effective Taxation of High-Net-Worth Individuals. Taxing the Super-rich’ under the 2025 Sevilla Platform for Action (SPA) at the fourth Financing For Development International Conference, can provide an effective means for participating countries to collaborate, coordinate and advance solutions to ensure that high net worth individuals pay their fair share.

Volume 54 Online ISSN 0165-2826

Debate: A Global Minimum Wealth Tax: Some Issues of Economics and Implementation [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Noting that many ultra-high net worth (UHNW) individuals pay very low effective rates of personal tax on their incomes, Zucman (2024, 2025) proposes a minimum wealth tax which ensures that UHNWs incur personal taxes of at least 2% of their worldwide wealth. This note discusses some anomalies of his hybrid income-and-wealth tax scheme, recounts some complexities in implementing and propagating it on a worldwide basis, given that individual wealth includes assets in many countries, and argues that there are other and no less appealing paths to much the same end, including taxing capital gains on accrual and enhancing inheritance taxation.

Volume 54 Online ISSN 0165-2826

Debate: A Critique of Gabriel Zucman’s 2% Billionaire Tax [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Zucman’s suggestion of a minimum tax on the ultra-wealthy is welcome in the quest for tax justice. This suggestion has the potential to address the wealth gap and to raise much-needed domestic revenue. However, it is couched within the context of a disharmonized international tax framework which may be ill equipped to address challenges such as multiple nationalities and residencies. This article argues that the adequacy of Zucman’s suggestion should be weighed against the scales of fiscal legitimacy and calls for the establishment of a global fiscal architecture.

Volume 54 Online ISSN 0165-2826

Literature Review: The Compatibility of Turnover-Based Business Taxes With EU Law and WTO Law, Balász Károlyi, IBFD Doctoral Series. 2024 [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Volume 54 Online ISSN 0165-2826

Debate: The Billionaire Tax: A (Modest) Proposal for the 21st Century [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Volume 54 Online ISSN 0165-2826

Debate: The Normative Case for a Global Minimum Tax on Ultra-High-Net-Worth Individuals [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Gabriel Zucman presents his proposal for a global minimum tax on billionaires as one that citizens must debate. They have to weigh the benefits and costs and ultimately decide whether to adopt it. In this article, we aim to contribute to this debate by discussing relevant insights from economic ethics and political philosophy. Our main claim is that the normative case for Zucman’s proposal is very strong because it is overdetermined: there are multiple reasons that are, if each is taken individually, sufficient to justify the proposal. Such a global minimum tax would help address unmet urgent needs, promote social cohesion and relational equality, contribute to climate fairness and ecological transitions, and improve the functioning of democracies. It would also bring the tax system closer in line with the ability-to-pay principle and help reduce undeserved wealth inequality. All these normative considerations combined show that citizens have good reasons to adopt the proposal. If anything, these considerations imply that citizens should, ultimately, aim for an ambitious variant of the proposal.

Volume 54 Online ISSN 0165-2826

Peer Review List 2025: Professor Noam Noked Receives the 2025 Intertax Award for Best Blind Review [pre-publication]

Sun, 14 Dec 2025 00:01:06 GMT

Volume 54 Online ISSN 0165-2826