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Tax treaty between Canada and US – US Tax Court rules AMT FTC limitation prevails over treaty

|Treaty Development|United States-Canada
United States-Canada

The US Tax Court has held that the 90% foreign tax credit (FTC) limitation on the alternative minimum tax (AMT) contained in Section 59 of the US Internal Revenue Code (IRC) prevails over the requirement in the 1980 US_Canada tax treaty to eliminate double taxation. William D. and Judith A. Jamieson v. Commissioner of Internal Revenue, Docket No. 16421-05 (29 April 2008).

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