U.S. Court of Appeals for the Federal Circuit

Estate of Paul Bruyea v. United States

August 31, 2026

Summary

The Federal Circuit reversed the Court of Federal Claims’ summary judgment awarding a refund of net investment income tax paid by a U.S. citizen residing in Canada. It held that the Internal Revenue Code does not authorize foreign tax credits against the net investment income tax and that the U.S.-Canada Convention makes treaty-based credits subject to the Code’s limitations. No separate opinions were filed.