Bound Ownership: A Fiscal Asset-Lock Without Legal Form Conversion

Modern capital tax systems intervene at the level of stocks (wealth), flows (income), or events (realisation, inheritance, disposal). They are structurally blind to the distinction between risk-bearing binding of capital and its detachment — i.e. the extraction of value from non-private use into private liquidity. This paper sketches a Bound Ownership (BO) regime that treats capital not as a scalar magnitude but as a state. Capital exists in one of two states: bound (risk-bearing, transferable only with assumption of obligations, with entry-time legal status preserved and low reinvestment friction) or unbound (extracted into private liquidity). Taxation triggers solely on the transition — the detachment event. Sale is fiscally neutral if the buyer assumes the bound obligation; for A6 continuity purposes the obligation is the fiscal continuity unit, while legal ownership and asset identification remain necessary for valuation and enforcement. The mechanism produces a fiscal asset-lock that requires no change of legal form, and is therefore potentially generic across existing ownership structures, subject to entity-specific enforcement rules. The architectural components — capital gains lock-in, generalised cash-flow taxation, rate-of-return allowances, steward ownership, asset locks, exit and migration taxes, BEPS-style anti-extraction enforcement, state-contingent contracting — exist in the public-economics, corporate-law, and law-and-economics literatures individually. I have not, on present literature mapping, identified an existing treatment that unifies these components as a state-contingent fiscal regime over capital without legal-form conversion. The claim is not originality of components but careful synthesis; refinement or refutation of the gap statement by adversarial review is welcomed. Contents (v0.2.2): an explicit canonical schema (labels A1–A9, with sub-component A6.1) integrated and used by these labels throughout; a formal two-state model (state space, transition map, detachment-tax function, three structural properties, two worked numerical examples); a verified literature map across fifteen clusters, each citation tied to specific A-components; an end-to-end engineering treatment of the reinvestment subproblem (E1) within the cash-only frame; three worked test cases. The architecture itself is unchanged from v0.1; subsequent revisions deepen the formal model and the literature map. The remaining engineering problems — valuation, anti-abuse enforcement, calibration, jurisdictional fit, transition design (E2–E7) — are stated and deferred to subsequent revisions; they are treated here as engineering and enforcement problems unless shown otherwise. The v0.3 generalisation to a substance-vector treatment of detachment is forward-noted at the points where it bears on the present architecture. Status: Working Paper v0.2.2. This version is deposited as a dated provenance anchor and working draft; subsequent revisions may revise terminology, scope, and engineering details.