The wealthiest American families don’t pay capital-gains tax the way the IRS table suggests. They use a strategy that has been documented in tax journals for decades: Buy, Borrow, Die. It’s not a loophole. It’s the deliberate output of how the U.S. tax code treats appreciation, debt, and inheritance.
The three steps
- Buy long-term appreciating assets — equities, real estate, art, and now Bitcoin and ETH.
- Borrow against those assets when you need liquidity. Loans are not income. The asset stays on your balance sheet.
- Die — the asset transfers to heirs at a stepped-up basis, meaning the embedded capital gain is wiped clean for tax purposes.
The combined effect: decades of compounding, decades of tax-deferred liquidity, and at the generational hand-off, the IRS’s claim on the appreciation evaporates.
How crypto fits
Bitcoin and Ethereum are long-duration appreciating assets. They’re globally liquid. They can serve as collateral for loans on-chain or off-chain. They sit cleanly inside trusts. The same playbook works — with caveats. Liquidation thresholds on crypto-backed loans are tighter than on stock margin lines. Custody matters more. Estate-planning structures for self-custodied assets are still developing.
What changes for crypto-native principals
For traditional securities, the bank’s pledged-asset line is well-paved infrastructure. For crypto, the principal needs to coordinate three layers: a custody arrangement that survives a 50% drawdown, a lending counterparty (centralized or DeFi protocol) with a defensible liquidation policy, and an estate structure that can transfer keys without forcing a sale.
What the strategy is not
Buy, Borrow, Die is not aggressive tax avoidance. It’s the natural result of holding appreciating assets, using debt instead of liquidation for spending, and passing the assets at death — every step well within published code. ARCrypto teaches the structure. We do not replace tax counsel; we hand them the framework they can defend.
Where to start
Read the Buy, Borrow, Die field notes on ArcBlog. For a private walkthrough of how this maps to your specific position, book a call.