https://www.taxtmi.com/forum/issue?id=117479 Conflict arises where domestic day count rules render an individual resident while the DTAA and facts of permanent residency and centre of vital interests abroad point to treaty based non resident treatment; treaty characterization governs taxing rights and gives rise to the practical issue of whether global income is taxable domestically and whether relief by way of foreign tax credit is available under domestic law. en-us Tue, 07 Sep 2021 17:18:53 +0530 Thu, 23 Jan 2025 15:54:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=117479 Conflict arises where domestic day count rules render an individual resident while the DTAA and facts of permanent residency and centre of vital interests abroad point to treaty based non resident treatment; treaty characterization governs taxing rights and gives rise to the practical issue of whether global income is taxable domestically and whether relief by way of foreign tax credit is available under domestic law. Discussion-Forum Income Tax Tue, 07 Sep 2021 17:18:53 +0530 https://www.taxtmi.com/forum/issue?id=117479