Would an unapportioned US federal wealth tax be constitutional, and what does that mean?

This article examines the constitutional issues surrounding an unapportioned federal wealth tax and a federal income tax provision that would tax unrealized capital gains of the wealthiest Americans. It highlights the ambiguity and contested interpretations of the U.S. Constitution's clauses on "direct taxes," focusing on the controversial 1895 Supreme Court case Pollock v. Farmers' Loan & Trust Co., which struck down an unapportioned income tax and has never been formally overruled, though widely criticized. The article also discusses the 1920 Eisner v. Macomber decision, which imposed a realization requirement for income taxation, and its uncertain current relevance to taxing unrealized gains. While prevailing legal doctrine might support a minimum income tax including unrealized gains, the article notes that the current Supreme Court's right-wing majority is likely to strike down such measures, reflecting broader political and interpretive conflicts within constitutional law.