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Furthermore, neither party commented on this Court's previous consideration of this issue in Abakhan: ‘[9] Further, I cannot conclude that Abakhan's application for judicial review runs contrary to Parliament's intent to confine late requests for reassessments to individuals. ...

Taking that into consideration we suggest that no taxpayers or only those taxpayers whose total income exceeds a certain threshold amount and who receive a significant amount of U.S. source employment income, business income effectively connected to a permanent establishment in the U.S., or rents or royalties from U.S. real property need to compute AlienTax taking into account the progressive tax rates in the U.S. ...