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Estate of Paul Bruyea v. US
Case Number:
25-1563
Court:
Nature of Suit:
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August 31, 2026
Canada, France Treaties Don't Ax Investment Tax, Court Says
U.S. tax treaties with Canada and France don't shield taxpayers from the net investment income tax because the treaties' foreign tax credits are subject to limitations in the Internal Revenue Code, the Court of Appeals for the Federal Circuit said Monday, reversing two decisions.
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March 03, 2026
Fed. Circ. Wrestles With Treaty Language In Tax Credit Fights
A Federal Circuit panel grappled Tuesday with how to interpret a phrase in the U.S. government's tax treaties with Canada and France that allows foreign tax credits subject to limitations in the Internal Revenue Code as it weighed two refund disputes.