[rapht]

I agree with you. This makes even more sense as in: if a lender lends you $x against a collateral of N shares, this means that they consider that there is only a tiny chance that said shares may be worth less than $x before the maturity of the debt. So this means that for all practical purposes we could decide that there are at least $x of realised gains. (In a more extreme version you could even consider that all your shares, and not just the N shares used as collateral, should be valued at $x/N per share and treat the gain as a capital gain for tax purposes)