“Whether the CFC erred in ruling that Article XXIV of the income tax treaty between the United States and Canada allows a U.S. citizen residing in Canada to claim a foreign tax credit (for taxes paid to Canada) to offset the net investment income tax imposed by § 1411 of the Internal Revenue Code, even though the Code itself does not allow such a credit.”
“[T]he Code does not allow Bruyea to apply a foreign tax credit for the taxes he paid to Canada (on the income he realized for his sale of property in Canada) as an offset to the net investment income tax he owes the U.S. under Code § 1411.”
