. >> it is ivan allen. >> we also said taxes, that partnerships can be taxed individually even when the partners are not receiving the property. we have sub set as and as and -- f and s and all different forms of wealth we have interpreted to individuals rather than to the legal forms of ownership. >> and all of those taxes rely on the principle that the court expressed in cases like horst and banks which is income should be taxed to he who earns it and enjoys its benefits. >> i wonder whether there is any realization requirement at all. there is quite a history in this country of congress taxing american shareholders on their gains from foreign corporations and you can see why. the u.s. government cannot tax foreign corporations directly. they wanted to make sure americans that have stashed their money in foreign corporations watched their money grow and never pay taxes on them. so, there is a long centuries-old history of these kinds of taxes on gains from your holdings in a foreign corporation. why is this any different? why shouldn't we understand that to be quite well-settled, that