Case: Taxpayer's Net Investment Income Tax Liability Subject to Offset by Treaty-Based Foreign Tax Credit (Fed. Cl.) (IRC §1411)

Plaintiff was entitled to a treaty-based foreign tax credit (FTC) against the net investment income tax (NIIT) imposed by I.R.C. §1411 because the Canada-U.S. tax treaty provides an independent basis for it, the U.S.
Read more...