In a post published on January 11, 2026 I discussed the problem of the United States attempt to deny U.S. citizens in Canada a foreign tax credit for Canadian tax paid on Canadian investment income. The post is here:
Does The Canada U.S. Tax Treaty Allow A Foreign Tax Credit Against The Net Investment Income Tax?
I mentioned that a U.S. court had ruled in “Bruyea” that the United States was obligated – as per the terms of the treaty – to allow a tax credit against U.S. tax for Canadian tax paid on that same income. Obviously, this decision was a threat to what the U.S. regards as it s right to impose double taxation on Americans abroad generally and on U.S. citizens living in Canada specifically.
The Bruyea is an incredibly significant case for both individuals living under the sanction of U.S. citizenship taxation and the countries where those U.S. citizens live.
The case was argued today March 3, 2026.
Here are the recordings of the oral arguments. Very interesting!
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Here is a podcast based on a March 4, 2026 X Spaces discussion about the cases that I had with Tim Smyth.