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The Supreme Court May Preemptively Ban a Federal Wealth Tax
(newrepublic.com)
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this post was submitted on 04 Jul 2023
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I could see a couple arguments. If the government argues it's an income tax under the 16th amendment you could probably argue somewhat convincingly that it is not yet income.
As a direct tax under Article I Section 8 it would probably be doomed as it would need to be subject to the rule of apportionment -- each state is required to be taxed equal to its percentage of the national population.
In order to survive you would either need to successfully argue that it is income or that it is an indirect tax (think excise taxes, customs duties, etc).
Would a national sales tax on purchases over 5 or 10 million pass muster do you think? Or is sales tax something that only state and local governments can impose?
Sales taxes should be fine.