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atamatax

Methodology changelog

Every engine change, on the record.

Our correction policyis simple: when a calculation issue is found, we fix the engine, add a regression test, and record it here — including the mistakes. A tax product that only publishes its wins isn't telling you anything.

Tax year 2025–2026

Sample report Form 8938 verdict made engine-consistent

The published sample report hardcoded “Form 8938 required: Yes” next to figures below the printed thresholds, and its asset total wrongly included US-domiciled holdings. The sample case now carries explicit foreign bank accounts, every threshold verdict is derived from the same rule the engine applies, and a regression suite replays the sample through the real engine so the two can never disagree again. The package PDF now also names the exact test crossed (end-of-year vs any-time) and explains how the specified-foreign-assets figure is composed.

Affected: Sample PFIC report · package PDF Form 8938/FBAR section · Verified against: IRS Form 8938 instructions (reporting thresholds for taxpayers living abroad)

Tax year 2025–2026

Form 8938 any-time test and foreign-only asset base

The FATCA threshold check previously ran the end-of-year test only and compared the total portfolio (including US-domiciled assets) against the threshold. It now runs both statutory tests — end-of-year and maximum-value-during-year — against specified foreign assets only, with foreign accounts contributing an explicit EOY balance when provided (never assumed equal to their maximum).

Affected: Form 8938 threshold check · triggered-forms detection · Verified against: IRS Form 8938 instructions; 26 CFR §1.6038D-2

Tax year 2025–2026

FBAR computed from entered accounts

FBAR previously surfaced as an unconditional attestation request. The engine now aggregates the maximum annual balance across entered foreign financial accounts and computes the $10,000 verdict, while still requesting confirmation that no accounts are missing.

Affected: FBAR (FinCEN 114) check · Verified against: 31 CFR §1010.350; FinCEN Form 114 instructions

Tax year 2025

PFIC elections now drive the computation (no fabricated §1291 worst case)

The QEF / mark-to-market / §1291 election previously did not change the computed tax, and a fixed-shape §1291 “worst case” was estimated from assumptions (5-year hold, zero prior distributions). Elections now branch the math: MtM includes the §1296 gain in ordinary income; QEF requires the fund's Annual Information Statement and is otherwise reported as needs-input; §1291 charges are computed only from actual dispositions with known acquisition dates and basis — never fabricated.

Affected: Form 8621 computation · per-holding election chooser · package PDF · Verified against: IRC §§1291, 1295, 1296; IRS Form 8621 instructions (Rev. Dec 2025)

Tax year 2025

§1291 excess-distribution charge on actual dispositions

Dispositions of a known PFIC with explicit acquisition date and cost basis are now taxed under the §1291 excess-distribution regime: gain allocated ratably over the holding period, prior-year slices taxed at each year's top statutory rate with §6621 underpayment interest compounded per year. PFIC dispositions are excluded from the normal capital-gain pass so nothing is taxed twice.

Affected: Form 8621 Part V · Schedule 2 line 17p · Verified against: IRC §1291(a),(c); IRC §6621 quarterly rate tables

Tax year 2025

FEIE (§911) stacking and NIIT (§1411) added

Form 2555 exclusion computed with the §911(f) stacking worksheet (tax on income including the add-back minus tax on the exclusion alone), capped at the year's maximum. NIIT computed as 3.8% of the lesser of net investment income and MAGI over the filing-status threshold — flagged needs-input when MAGI is not supplied rather than approximated.

Affected: Form 2555 · Form 8960 · 1040 summary · Verified against: IRC §911(f); IRC §1411; Form 2555 instructions

Tax year 2025

Golden-test harness for tax math

Introduced hand-derived reference cases cross-checked against independent bracket calculators before being committed — federal brackets, LT capital-gain stacking, Form 1116 credit cap, FIFO realized gains, threshold arithmetic. Every engine change since must pass this suite.

Affected: Entire tax engine · Verified against: Rev. Proc. 2024-40 (2025 inflation adjustments)

Last reviewed . Known limitations are listed per form on the supported-forms page.