... but there remains the issue of Satoshi dying and creating a massive capital gains / estate tax liability. When it comes to Satoshi's coins I am far more concerned about Satoshi's estate than Satoshi.
Satoshi's coins are forever a dark cloud hanging over the markets, I think he deserves his fortune but it is what it is, like any coin with premine or instamine these coins could be dumped at any time, we can't ever be sure if he still has the private keys or someone else is or will be in possession of them and will ever move or dump the coins, it is an eternal state of uncertainty.