Accrued Gains are not Income: An Administratively Simple Rollover Treatment for Capital Gains Taxation
Bibliographic record
Abstract
This paper presents a definition of income that rejects both the BEA and Haig-Simons definitions concerning capital gains. Specifically, capital gains represent future income unless brought to the present by consumption of the gain. We demonstrate that the rollover treatment implied by this definition ends double-taxation, under-taxation, lock-in of capital, excessive incentives to consume capital, and other economic distortions. Finally, we detail an administratively-simple deferred gain account rule for the rollover treatment which would require that taxpayers only track one additional item of information – the total deferred gain that would be rolled over into the next tax year.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.003 | 0.008 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.002 | 0.006 |
| Scholarly communication | 0.005 | 0.007 |
| Open science | 0.002 | 0.003 |
| Research integrity | 0.002 | 0.007 |
| Insufficient payload (model declined to judge) | 0.005 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".