The Friday Edition
A biweekly newsletter for international tax professionals
What’s New This Week?
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Christensen and Bruyea reversed; no foreign tax credit for NIIT
Welcome to The Friday Edition. Phil Hodgen here. More international tax stuff for practitioners and aficionados. Let’s keep it brief this week: So let’s keep it short. No foreign tax credit for net investment income tax The net investment income tax is a nasty piece of work. It imposes an income tax on investment income (interest, dividends, capital gains), but does not allow a foreign tax credit if another country also imposes income tax on that investment income. Why? Because IRC Section 1411 imposes “an” income tax on this special category of income, in addition to “the” income tax imposed…