Unravelling the Mysteries of the Treaty-Based Foreign Tax Credit

Tax Treaties vs. the Internal Revenue Code: Bruyea v. United States

Unravelling the Mysteries of the Treaty-Based Foreign Tax Credit

This panel will examine the Court of Federal Claims’ decision in Bruyea, which allowed the taxpayer to use a “treaty-based foreign tax credit” to offset liability for the net investment income tax. The panel will also explain how the courts resolve potential conflicts between tax treaties and the Internal Revenue Code and why the so-called “later in time rule” is extremely misleading.

Speaker:

Michael J. Miller, Partner, Roberts & Holland, LLP

Moderator: Alan I. Appel '76, Professor of Law; Director, International Tax Program, New York Law School

This program will offer 1.5 Professional Practice CLE Credits (NY Transitional and Nontransitional). A light lunch will be served.

Host or Publisher Graduate Tax Program