Do you think that (e.g.) student loans should be counted as "income", given that they have much in common with a fully-collateralized loan?

(the collateral in this case is all of the borrower's future income, given that student loans cannot be discharged in bankruptcy).

It can get tricky quickly. Imo there are two solutions here. First option is to count it as income that then gets written off as a business expense. Second is to flesh out what fully collateralized means to better express it as an alternative to selling something. I think the first option makes sense. There are many scenarios where businesses will take fully collateralized loans and then reinvest the proceeds, that shouldn't be taxed. But if the loans are just turned into profit they should be.

> But if the loans are just turned into profit they should be.

What if the student loans are turned into beer?

Should they then be considered "income"?

If you think this sounds facetious, you've never been on a college campus the day the student loan checks hit the banks.