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Treaty between Australia and US – No treaty relief for US tax paid

|Treaty Development|Australia-US
Australia-US

The Australian Taxation Office (ATO) released its Interpretative Decision ATO ID 2008/57, which states that the Australia-United States tax treaty does not provide for a foreign tax credit in Australia in respect of a US tax paid by an Australian resident.

The taxpayer in question was a citizen of the US and a resident in Australia under the treaty. The taxpayer made a cap…

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