PFIC calculations: the IRS gets hoisted by its own petard

We congratulate our colleagues, tax attorneys Robert S. Schwartz & Elizabeth C. Petite, on a great win in US tax court in the case of Roberto Toso and Marcela Salman v. Commissioner, US Tax Court, Dkt. 8324-15 151 TC ___ No. 4, September 4, 2018. What makes their win so refreshing is that the convoluted Passive Foreign Investment Company (PFICs) reporting rules are the exact reason why the IRS was forbidden from going way back to assess additional taxes.

US Green Card holders & IRS issues: Why they can be so tricky

US Expatriates have rights been garnering a tremendous amount of attention towards the ridiculously complicated tax compliance regime they are subjected to. We like to think we are somewhat responsible. But one group – US Green Card holders – officially known as US Permanent Residents, often have more difficult problems. And, because they aren’t US citizens and can not vote, have little recourse. This is not a good thing for the country as we explain.

Something lighter: Is the tax premise to Happy Gilmore at all plausible?

The US Tax Code can get a bit overwhelming. Which is why we like to pull back a little sometimes and have a little fun. Up today: An in-depth analysis of the tax premise of the 1996 Adam Sandler vehicle, Happy Gilmore. After careful review of the relevant facts, we determined that the tax premise that compels Happy to abandon hockey in order to become a champion golf player is plausible. We also show how it is possible for grandma to keep her house, even if she wasn’t as lucky to have a grandson as fantastic as Happy.