Fed. Circ. Wrestles With Treaty Language In Tax Credit Fights

By Natalie Olivo · March 3, 2026, 6:34 PM EST

A Federal Circuit panel grappled Tuesday with how to interpret a phrase in the U.S. government's tax treaties with Canada and France that allows foreign tax credits subject to limitations in...

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Case Information

Case Title

Christensen v. US

Case Number

24-1284

Court

Appellate - Federal Circuit

Nature of Suit

212 Tax - Income, Individual

Date Filed

December 22, 2023


Case Title

Bruyea v. US

Case Number

25-1563

Court

Appellate - Federal Circuit

Nature of Suit

212 Tax - Income, Individual

Date Filed

March 20, 2025