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 (v1.0.1) The canonical schema A1–A9 with sub-component A6.1. The per-class substance vector S(a, t) and detachment-tax function. The Symmetric Valuation Regime with BZBB methodology-consistency audit, Big-4 joint-and-several liability, and reverse-burden A3 reclassification. The Anti-Extraction Bright-Line Catalogue BL.1–BL.11. The Pillar 2 SBIE compatibility argument. The Political Economy section with the Hybrid Pilot 2027–2032 adoption sequence. Two expansion vectors: Public Bound Registry, Worker / Citizen Bound Shares. A reduced-form game-theoretic backbone with Theorem 1 (Methodology-Switch Arbitrage Collapse under Symmetric Valuation) and three comparative-statics results. An empirical calibration sketch on composite firm archetypes with r-window characterisation and Phase 1 aggregate band. A constitutional compatibility sketch under GG Art. 14 Inhaltsbestimmung, Art. 3 sachgerecht differentiation, EU Grundfreiheiten, and BVerfG transitional jurisprudence. Executive Summary and extended glossary with reader-path navigation. Companion-paper candidates This document is a master working draft intended as a source for narrower academic, policy, and implementation papers. Four specialist-companion candidate work-packages are explicitly named and bounded: S4.1 — Full mechanism-design treatment. S4.2 — Empirical calibration on Bundesbank-FRSL micro-data. S4.3 — Full constitutional-law Verfassungsgutachten. S4.4 — Comparative implementation analysis across NL / CH / AT / KE. Status Working Paper v1.0.1. Anchored against v0.2.2 (DOI 10.5281/zenodo.20098636, timestamp anchor); v0.3 is the substantive-architectural predecessor (local-only, not deposited); v1.0.1 adds three reduced-form analytical layers (game-theoretic backbone, empirical calibration sketch, constitutional compatibility sketch) and is the distribution-ready master source. Please cite the version DOI when referencing this draft; later versions may revise terminology, scope, and engineering details.