The External Gains assumption is a major and controversial factor in the calculation of tax alpha.
Without any external gains, deductible capital losses are limited to $3,000 per tax year.
With the assumption that unlimited long-term gains are available for offset,
all realized losses are used to avoid taxes at the preferential long-term gains rate.
The assumption of unlimited short-term gains leads to the largest estimates of tax alpha.
With this assumption, all realized losses are used to avoid taxes at the higher short-term gains rate.
Without external gains, tax loss harvesting can only exploit the $3,000 loss allowance.
The significance of the loss allowance to tax alpha decreases as portfolio size increases.