Ok, I’m just going to go ahead and pitch an alternative and then you can weigh in on the relative merits.

In my mind, the issues aren’t the loans themselves, it’s that they’re secured by shares. Billionaires are able to realize real value from those shares without paying taxes in them.

I think if you want to use shares as collateral, you need to pay the taxes on them.

You wanna use shares to back a loan, fine, but the instant you do, all taxes on those shares are due at FMV.