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CASE REVIEW – IRS WINS FOREIGN TAX CREDIT NIIT CASE ON APPEAL

Sep 07, 2026

In this week's blog, we analyze two appellate decisions concluding that neither the U.S.-Canada nor the U.S.-France tax treaties allow Americans living abroad to use foreign tax credits to offset the net investment income tax.

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CASE REVIEW – TAXPAYER WINS FOREIGN TAX CREDIT NIIT CASE

Dec 26, 2024

In this week’s blog, we review a case representing a major win for taxpayers, in which the U.S. Court of Federal Claims concluded that a treaty allows foreign tax credits to offset the net investment income tax.

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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Aug 26, 2024

In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, as well as the impact the decision could have on current filers, particularly those catching up using the Streamlined Procedures.

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CASE REVIEW – IRS WINS FOREIGN TAX CREDIT NIIT CASE ON APPEAL

CASE REVIEW – TAXPAYER WINS FOREIGN TAX CREDIT NIIT CASE

SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

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