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Elimination of double taxation: foreign tax credit allowed to offset domestic tax, limited to tax attributable to that income. The Agreement requires reciprocal elimination of double taxation by permitting a foreign tax credit: the State of residence shall allow as a deduction from domestic tax an amount equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to that income. Additionally, where income is exempt in the State of residence under the Agreement, that exempt income may be taken into account in computing tax on the resident's remaining income.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: foreign tax credit allowed to offset domestic tax, limited to tax attributable to that income.
The Agreement requires reciprocal elimination of double taxation by permitting a foreign tax credit: the State of residence shall allow as a deduction from domestic tax an amount equal to tax paid in the other Contracting State, limited to the portion of domestic tax attributable to that income. Additionally, where income is exempt in the State of residence under the Agreement, that exempt income may be taken into account in computing tax on the resident's remaining income.
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