Canada, France Treaties Don't Ax Investment Tax, Court Says

By Kevin Pinner · August 31, 2026, 6:01 PM EDT

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,...

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Case Information

Case Title

Christensen v. US

Case Number

24-1284

Court

Appellate - Federal Circuit

Nature of Suit

212 Tax - Income, Individual

Date Filed

December 22, 2023


Case Title

Estate of Paul Bruyea v. US

Case Number

25-1563

Court

Appellate - Federal Circuit

Nature of Suit

212 Tax - Income, Individual

Date Filed

March 20, 2025