The realization requirement and the basis step-up together allow appreciation held by the wealthiest taxpayers to be deferred across a lifetime and forgiven at death, and the borrowing that funds consumption in between is not itself a taxable event. Around that core sit the preferential rate on capital gains, carried interest, and a set of more aggressive techniques now drawing government attention — among them the use of Section 852(b)(6) in ETF structures, Section 351 seeding, and box-spread and related option strategies. This panel takes brief account of the principal devices and then turns to the question that matters here: whether what they describe is a defect in the income tax or a set of deliberate design choices with defensible reasons behind them, which is genuinely contested. The panel considers what the data do and do not establish about concentration at the top and how much of it the tax system explains, then works through the principal responses on the table — mark-to-market and minimum taxes on unrealized appreciation, repeal or modification of the step-up, carried interest reform, and wealth taxation — and the efficiency, valuation, administrability, and constitutional objections each must answer after Moore v. United States. The panel closes on the harder question: whether tax is the right instrument for this problem at all, or whether the framing itself obscures more than it reveals. Attendees interested in the mechanics of the ETF and option structures noted above should see the Day 2 breakout session, Section 852(b)(6) Under the Microscope: ETF Planning in Focus.