Deal Law
I would love to QEF your PFIC
This isn't a "non-story" to the tax bar. This is actually a very interesting case (for someone like me anyway). The Bruins actually appear to have a pretty good argument, just from my cursory reading of the 274 regs (this isn't an issue I've ever had to research previously, and I don't plan on it now). This is an actual story for tax attorneys and tax accountants and should be for professional sports franchises, given the concept of stare decisis