Elimination of Double Taxation prescribes credit and exemption-with-progression mechanisms under the tax treaty to avoid dual taxation. Elimination of Double Taxation is effected by a foreign tax credit allowing a deduction equal to tax paid in the other State, limited to the portion of domestic tax attributable to income taxed abroad, and by an exemption-with-progression rule permitting the resident State to take exempted income into account when computing tax on the remaining income.
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Provisions expressly mentioned in the judgment/order text.
Elimination of Double Taxation prescribes credit and exemption-with-progression mechanisms under the tax treaty to avoid dual taxation.
Elimination of Double Taxation is effected by a foreign tax credit allowing a deduction equal to tax paid in the other State, limited to the portion of domestic tax attributable to income taxed abroad, and by an exemption-with-progression rule permitting the resident State to take exempted income into account when computing tax on the remaining income.
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