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

The USA now has ten occasions as many billionaires because it had just some many years in the past. This ever-growing class has sparked congressional curiosity in “billionaire tax” proposals. These proposals would usually require that billionaires acknowledge revenue when their asset values improve, even when they haven’t bought their property.

Underneath present doctrine, billionaire taxes doubtless 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 strategy superior on this Article, a billionaire tax would go constitutional muster.