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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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CASE REVIEW – COURT CONSIDERS IF FOREIGN TAX CREDITS CAN REDUCE THE NIIT

Dec 28, 2023

In this week’s blog, we review a recent intriguing decision, in which the U.S. Court of Federal Claims tackled the issue of whether a tax treaty can be used to allow a foreign tax credit to offset the net investment income tax.

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

CASE REVIEW – TAXPAYER WINS FOREIGN TAX CREDIT NIIT CASE

CASE REVIEW – COURT CONSIDERS IF FOREIGN TAX CREDITS CAN REDUCE THE NIIT

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