Bruyea v. United States

 
APPEAL NO.
25-1563
OP. BELOW
CFC
OPINION
SUBJECT
Tax
AUTHOR
TBD

Issue(s) Presented

“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 ยง 1411 of the Internal Revenue Code, even though the Code itself does not allow such a credit.”