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India - Supreme Court Lays To Rest The Most Favoured Nation Controversy.

India - Supreme Court Lays To Rest The Most Favoured Nation Controversy. Legal News and Analysis - India - Tax - ....

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Tax credit did not independently arise under treaties

Given the proliferation of use of the model treaty language, most U.S. citizens living abroad will continue to find a foreign tax credit unavailable against their net investment income, even when that income is taxed by other countries. ....

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Tax treaties do not provide a foreign tax credit against net investment income tax

A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties. ....

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