Liberty and justice for all United States persons abroad

Bruyea Case Argued – March 3, 2026 at 10 am Eastern – Here Are The Recordings

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!

____________________________________________________

 

Here is a podcast based on a March 4, 2026 X Spaces discussion about the cases that I had with Tim Smyth.

 

 

John Richardson

 

 

 

Leave a comment

Your email address will not be published. Required fields are marked *