Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141 -- summary under Subsection 126(1)

a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income

The taxpayer was an Australian resident who was taxed at the 15% long-term U.S. capital gains rate on his gains on disposal of U.S. oil and gas...

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Tax Topics - Treaties - Income Tax Conventions - Article 24 foreign tax credit was not required to be accorded to all the US tax on the gain 361