I spent some more time with the NIIT proposed regulations and I also reviewed quite a few alerts by reputable firms and articles by renowned tax practitioners.  There are two buzz words that popped up in my NIIT adventures: “S-corporation” and “grouping activities.”  It seems like practitioners are focused on these two elements in their tax planning pitches to potential clients looking to minimize NIIT.  I have my doubts about carrying out any tax planning based on proposed regulations, considering that the regulations could change, and in the interim Treasury would have the...