Relief from double taxation: foreign tax credits and source deeming to prevent reciprocal taxation under the tax treaty. Article 23 requires the United States, subject to domestic law limitations, to allow a resident or citizen a credit against U.S. tax for income taxes paid or accrued to the other Contracting State, including taxes on profits out of which dividends are paid where a U.S. company owns at least ten percent of voting stock. Items of gross income taxable in the other State are deemed to be income from sources in that State for applying the credit rules, and special sequencing and deeming rules apply where a U.S. citizen is also a resident of the other State to avoid double taxation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Relief from double taxation: foreign tax credits and source deeming to prevent reciprocal taxation under the tax treaty.
Article 23 requires the United States, subject to domestic law limitations, to allow a resident or citizen a credit against U.S. tax for income taxes paid or accrued to the other Contracting State, including taxes on profits out of which dividends are paid where a U.S. company owns at least ten percent of voting stock. Items of gross income taxable in the other State are deemed to be income from sources in that State for applying the credit rules, and special sequencing and deeming rules apply where a U.S. citizen is also a resident of the other State to avoid double taxation.
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