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One of the primary mechanisms for tax avoidance is taking out loans against appreciated capital assets to avoid realizing capital gains.

What's stopping the average citizen from exploiting this tax avoidance strategy?

For example, every time I try to submit an order to sell stock that results in short-term capital gains, my broker should be asking me whether I want to take out a collateralized loan instead.

If there are loopholes in the tax system, they should be made readily accessible to all.



The average citizen can't borrow to pay off debts indefinitely.

At ~2% interest the billionaire can borrow against their assets and keep borrowing to pay off interest. The assets gain in value at 4-6% per year so they are actually coming out ahead and paying 0% tax.

Even a middle class retiree typically needs to draw down their savings to pay expenses. Giving up 2% to avoid taxes wouldn't be viable. The bank would also observe that there is a higher risk that the retiree goes bust than a billionaire and not lend enough money for the scheme to be worthwhile.


or even at all! large amount of Americans don't even have access to banking.

The loans they can get are insanely (i think disgustingly) predatory.

payday loans with fees can ed up being like 664% APR!!!!! Your 500 loan becomes 2000 you have to pay back in a couple months, which you obviously can't..

https://www.cnbc.com/2021/02/16/map-shows-typical-payday-loa...


Right it's crucially important we leapfrog all this crypto and fintech nonsense by just doing "fed accounts for all" administered electronically and at the post office.

Boring commercial banking should be utility, and any private sector offering will have to compete with a new non-grifter baseline.


And 2% is really high. Billionaires are likely getting less than 1% interest rates. Big banks are willing to lose money even, just to court these billionaires.


My Etrade account has that option. But I don't use it because it's risky. If you take out a loan collateralized by a stock, the stock could drop and you'd owe a lot of money.

Selling the stock locks in the gain. Now, if you only need say 1/2 the value as cash and can absorb the risk of the stock going down, then it makes sense. Or if you want to "buy insurance" by taking out an opposite short position, that would also make sense. But that short position will cost you money too.

So it's not as straightforward as "just take out a loan". You need a very good (and expensive) tax accountant to run the numbers and figure out the best strategy for your situation. Most people can't afford that.


Why isn't there an option to take out a loan where a repayment option is to transfer the capital asset (at whatever the value happens to be at the time of repayment)?

I.e. I don't get why the risky part of this loan can't be mitigated by the bank taking on the risk and managing it separately. Surely, there would be investors willing to back these types of collateralized loans?


You'd need a crazy high interest rate to account for market volatility. If the bank could make accurate predictions as to the future value of the stock, they would just invest in the stocks.

Loans against other assets are much less risky, because they are backed by actual things. If the bank screws up in predicting the future value of a house, they can still own the actual house and land if you default. With stocks it would be far more risky because stocks are far more volatile than houses.


Hm, is it possible to define a range for "crazy high interest"? As the debtor, I'd be willing to pay up to the difference in long-term and short-term capital gains (~15%). I guess where I'm going with this is: I don't understand why the average person ever pays short-term capital gains tax.


> I don't understand why the average person ever pays short-term capital gains tax.

Because the risk of holding the stock is more than the difference in short vs long term capital gains.

If the stock is worth $1000 in gains, I know I can sell it and lock in the gains today and pay my normal income rate. If I have to hold it for another 6 months, there is a huge risk that it drops more than the 5-10% difference in the tax rate for the average person.


I pay STCG on option contracts written and on (profitable) short sales (where the holding period is defined to be short-term).

Other positions have a defined thesis and, if that thesis gets invalidated, I close out the position sometimes at a gain. I do try to make most of my gains be LTCG, but trying too hard to optimize capital gains rates can lead to poorer investment decision-making/asset allocation.


You can simulate what you want by simultaneously buying an at-the-money protective put and selling an at-the-money covered call. Then regardless of future stock price movement, at expiration (i.e. when the "loan" needs to be repaid) you always transfer the stock away.

Now why don't you plug in this scenario into any Black–Scholes calculator and see how much of a net credit at entry you get (if you even have one). That would be the maximum loan amount you'd be able to get under this scheme. If you could get one at all, the loan amount is tiny compared to the value of the asset.


> ... bank taking on the risk...

Banks don't take on risk. Seriously.

That's another conversation to have, but the simple answer is do you want the value of your checking account impacted by someone else's purchase of Gamestop, or Enron?

And that's why banks don't take risk.


Banks loan money, and every loan includes some risk. If banks didn’t take on risk than the 2007/2008 bailouts wouldn’t have happened.


I should have clarified - banks don't take on market risk.


Taking the short position on a stock you own is called selling short against the box. I don't know much about it, just had heard of it, but it sounds like it's been regulated in the US (to reduce its use for tax avoidance) since 1997.

https://www.investopedia.com/terms/s/sellagainstthebox.asp


"What's stopping the average citizen from exploiting this tax avoidance strategy?"

Probably that the average citizen doesn't have capital gains.



most of those will be in retirement plans which I assume aren't taxed?


> which I assume aren't taxed?

It depends on which kind of retirement account. Might be in Roths and Roths-401Ks which are taxed when the money goes in (treated as regular income), or IRAs and regular 401Ks which are taxed as regular income when the money comes out.


But neither Roth nor Traditional 401k/403b/457/IRA are subject to capital gains tax.


If you are in the US you should brush up on your personal finances.


Certainly not capital gains of the order of "all the spending money I need, without any worry about repaying it on time even if the asset goes back down in price."


Your example of loans is tax deferral, not avoidance. As for your examples in general, those are really good.

Collateralized loans on stock we usually call "margin loans" and are easy to get.

Also, anyone in real estate will recognize the term "HELOC", where you can get a loan against the value of your home, presumably after its value has appreciated.

I think both of those are fairly accessible, at least in the US.


For the mega-rich it's tax avoidance. That money gets rolled into the estate or trust with the cost-basis resetting on death.


That's not a tax loophole though. You still have to pay back the loan with interest. And it has to be paid with cash from somewhere. People like Bezos do this primarily to retain their equity because it's worth more than money to them. It's their ownership stake. For others, they are just betting the assets will appreciate more than the cost of the interest. It's income optimization not tax avoidance.

You can do the same thing with a HELOC. Otherwise you'd have to sell your house and pay cap gains then spend the net profit. I don't think a HELOC is tax dodge.


HELOC definitely isn't a tax dodge because the first $250k-$500k of profit on the sale of your home is not taxable anyway.

But there is something to be said about being able to defer taxes effectively forever. Only the ultra-wealthy are able to do this.


This doesn't defer taxes, it defers realizing profits. The loan payments have to be made with cash that came from some source which can likely be taxed. Anyone with assets can do this proportional to their assets. Admittedly most people don't have sufficient assets to make it worthwhile. Nor do they exercise the voting rights on stocks. But really any middle class investor with a nest egg could do it.


You can:

https://www.schwab.com/pledged-asset-line https://www.wealthfront.com/portfolio-line-of-credit

And HELOCs are essentially the same for people who own a house but not stocks.


Got it, but why don't brokers more aggressively push this program onto clients? It seems like a win-win.

The debtor avoids the elevated short-term capital gains tax.

The bank gets interest payments on a loan that has an almost 0 default rate due to the loan being fully collateralized.


You're basically describing a margin account. If you have a portfolio on a margin account at the broker, you can just withdraw money from it up to the amount that your margin allows. That automatically starts a loan for that amount, collateralised by your portfolio.

The problem is that this is not nearly the same as selling stock and withdrawing the sales money, because you keep the risk that the stock will go down thus force liquidating your portfolio. You're conflating selling and borrowing, they're not identical except in these very vague tales about the ultra-rich.


> why don't brokers more aggressively push this program onto clients

They do.

Wealthfront (as just one example) features and advertises this prominently in their app.

It's also very easy to do with Robinhood, simply withdraw cash using your margin. Interest rates are quite low. 2.5% with Robinhood, 3.65% with Wealthfront.

There's a big "Borrow cash" button right when you open the Wealthfront app.


> It seems like a win-win.

It's not a win-win, there's significant risk.

> fully collateralized

This is not true! The underlying asset fluctuates in value and is open to lowering significantly in value, leaving the bank holding the bag.


> leaving the bank holding the bag

You probably underestimate the ability of banks to evaluate risk. Yes, they absolutely could end up underwater on an asset backed loan, but you also shouldn't assume that you can take out $1 in loans on every $1 of stock.

On Schwab's page, they say: "Schwab Bank, in its sole discretion, will determine what collateral is eligible collateral and the loan value of collateral". So, if you have some recently highly-appreciated shares of AMC for example, they might decide they are not eligible collateral, or only offer to lend you $1 for every $5 of stock.


LOL, yeah the banks have been so great at leverage in the past couple of decades in the USA that they have to get bailed out repeatedly.


Depends on what you spend the money on. If you take the margin and spend it on an asset, then you have the underlying stock as well as the asset to cover calls. Still requires correct thinking but the risk is mostly based on what you do with the loan.


I've been saying this for years. Low interest rates are like a triple handout to the extremely wealthy.

1) pump up asset prices.

2) lower the rate at which you can borrow against unrealized gains to make avoiding taxes more attractive.

3) people use this savings to buy more assets. Repeat step 1. Virtuous cycle.

I can't go to a bank and get a loan against $1M in my 401k at 2% interest. But I know people with $50M+ that are doing this. It's absurd.


Can you explain how this works, how it avoids tax? Taking a $100 loan still means you’ll need an income of $100 (plus interest) future income and tax paid on this income...

If you’re gonna say “they benefit in the extra capital gains between now and when the loan is repaid” - no, that can’t be it, that’s exactly equivalent to taking a $100 loan and investing in stocks instead (i.e. leverage).


1) You purchased $100 of SPY on June 15th, 2020

2) You're buying a house, and you need $100 today.

3) You sell $100 of SPY, and pay short-term capital gains (up to 37%)

OR...

1) You purchased $100 of SPY on June 15th, 2020

2) You're buying a house, and you need $100 today.

3) You take a loan for $100

4) You wait until June 15th, 2021 and then sell $100 of your SPY holdings, paying long-term capital gains (15-20%)

5) You repay the $100 loan

...it doesn't really avoid tax. It's just an alternative way of accessing capital by taking out a loan instead of liquidating assets.


That's not accurate. It has several benefits (like interest payments being deductible expenses) and wealthy people can continuously borrow to pay off other debts as their other assets appreciate. You just need the rate of appreciation of your assets to be higher than the interest rate. For very big loans, it's quite possible.

Finally, it's also possible to roll the gains into a trust and the cost basis is adjusted to zero on death. [0] So yes, it's tax avoidance.

[0]: E.g. this is how it's possible to do that: https://wellergroupllc.com/taxes-resources/tax140-guide-dete...


The above basically arbitrages long-term vs short-term capgains for the price of 1 APY cycle, right? That's ~23% for short in the USA, and up to income-level (37%?) for short-term. Quite a big difference for a 2-5% APY loan that you close after 1 year, and the numbers would seem to scale better the higher you go.


But if the asset sale + the debt leaves you at a loss wouldn't you be able to avoid paying the capital gaibs over the asset sale?


The theoretical assumes SPY increased over the time period. If it decreased, you could of course sell it and pay 0% since your investment lost money, short/long-term gains wouldn’t matter because there wouldn’t be any gains.

I might be misunderstanding your question though.


Debt is not a loss unless you default on it.


https://youtu.be/8pBPZMUcsh0 They never sell, they borrow over that invested money and pay 3% (interest) instead of 37% (income tax)


The assumption is that you are using the money for an income generating activity like buying a rental property.


The correct expression to use to refer to such money is “loan”, not “tax evasion”.


Hm, but income from rental is also taxed, isn't it? If so, how does it help?


The income from the rental is taxed, but slowly over decades. You don't have to take that entire tax hit in one year.


Also, people buying rental property from cash they earned from wages or selling their business pay tax on the wages/gains and the rental income, not just the latter...


You can also sell it and take the gains tax free in many cases.


Short of a 1031 exchange, I'm not sure how you would do that.


You can sell a house every 2 years and write off up to $500k in capital gains as long as it’s been your primary residence for 2 of the last 5 years. Doesn’t need to be consecutive.


Sure, but you have to stomach the 6% commission you’re paying to the brokers, which really limits this situation to transitory market conditions instead of a get rich quick strategy.


Chances are it doesn't, but the IRS won't go after rich people if they claim they don't have any taxes to pay.


> What's stopping the average citizen from exploiting this tax avoidance strategy?

If your stocks go down, you still owe the full amount of the loan. If your stocks go to zero, you still owe the full amount of the loan.


Also available in the UK, Interactive Brokers margin loan. The interest rate is 1-2% p.a.


Um, at various times I have had a home equity loan...


If one’s broker had collateralized loans in their menu of options, what volume of gains are needed to overcome the initial setup costs of the loan?




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