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D.C. Circuit: AMT Trumps Tax Treaty

The D.C. Circuit on Friday affirmed a Tax Court decision (T.C. Memo. 2008-118) that the § 59(a)(2) limitation of the foreign tax credit to 90% of the taxpayer’s AMT liability trumped the U.S.-Canada tax treaty.  Jamieson v. Commissioner,  No. 08-1253 (D.C. Cir. Oct, 16, 2009).


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