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Selected US Tax Developments: Bruyea Confirms Treaty-Based Credits for US Citizens in Canada—A Sequel to Christensen

Jonathan Rhein & Zaira Cortés

Canadian Tax Journal2025https://doi.org/10.32721/ctj.2025.73.4.ustdarticle
ABDC A*
Weight
0.50

Abstract

US citizens residing in Canada have faced uncertainty whether foreign tax credits can be used against the US net investment income tax. While US domestic law does not permit it, the US Court of Federal Claims in two cases, Christensen and Bruyea, held that US tax treaties with France and Canada create a foreign tax credit against the net investment income tax. With these cases now on appeal, the Federal Circuit will review the decisions of the Court of Federal Claims. A final decision in Bruyea will affect Canadian-resident US citizens evaluating future credit positions and refund claims with respect to the net investment income tax.

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https://doi.org/https://doi.org/10.32721/ctj.2025.73.4.ustd

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@article{jonathan2025,
  title        = {{Selected US Tax Developments: Bruyea Confirms Treaty-Based Credits for US Citizens in Canada—A Sequel to Christensen}},
  author       = {Jonathan Rhein & Zaira Cortés},
  journal      = {Canadian Tax Journal},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.32721/ctj.2025.73.4.ustd},
}

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Selected US Tax Developments: Bruyea Confirms Treaty-Based Credits for US Citizens in Canada—A Sequel to Christensen

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

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