U.S. taxes for American citizens living abroad include the Net Investment Income Tax (NIIT), 3.8% to certain net investment income of individuals, estates and trusts that have high income. Foreign tax credits from various specific countries have not usually been widely usable in offsetting NIIT liability.   But the U.S. Court of Federal Claims has decided, in Paul Bruyea v. United States, that foreign tax credits might be used to offset NIIT in U.S. tax treaties with more tha

Developments continue with the U.S. Corporate Transparency Act and its reporting requirement even as the reporting deadline is extended and