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Re:The IRS Tried to Take on the Ultrawealthy – It Didn’t Go ... by jdsully on Friday April 05, 2019 @12:47PM (#19584418)
Yes but the dimensions of a fuel tank are straightforward. The rules for a PFIC are intentionally designed by congress to be byzantine (to protect US investment funds).

The two rulesets are following different ethical norms.

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