In President Joe Biden’s proposal in the Fiscal Year 2025 Budget of the United States Government, and more specifically in the General Explanations of the Administration’s FY 2025 Revenue Proposals, the Biden administration has proposed a slate of bold shifts in tax policy that could redefine high income tax planning and investment strategies. Among the most striking initiatives in the FY2025 Budget Proposal is a set of proposals taxing unrealized gains—a concept ---SNIP-- . A shift in tax policy towards tapping revenue streams in unrealized gains is almost certainly on the horizon-