Zeev, You said "But you are right, he cannot have more than $10 MM per year in super capital gains (g)." I'm not a tax expert but how can he have 10MM of gains and still be in the 15% bracket? <A HREF="http://overseasdigest.com/odarticles/capital1.htm" target="_new">http://overseasdigest.com/odarticles/capital1.htm</A> Has there been a new law since the 1997 act?