Bruyea v. United States - Latest Foreign Tax Credit Case on the NIIT Sheds Important Light on Treaty Double Tax Articles
Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8% net investment income tax ( …