Bruyea - Treaty Tension: Does the U.S.-Canada Tax Treaty Cover the Net Investment Income Tax?

March 3, 2026 - Oral argument in the United States Court Of Appeals In Bruyea ...   AI generated description of the hearing:   "This episode covers oral arguments in a case about whether the U.S.–Canada tax treaty allows a foreign tax credit to be applied against the U.S. net investment income tax (Section 1411), which Congress placed outside Chapter 1 of the Internal Revenue Code. Advocates debate whether the treaty phrase "in accordance with the provisions and subject to the limitations of U.S. law" limits credits to Chapter 1 taxes or can be read more broadly to prevent double taxation; the discussion examines treaty text, the technical explanation, paragraphs 4–6, reciprocity concerns, and possible remedies."