A recent ruling in 2023 by the U.S. Court of Federal Claims allowed U.S. citizens living in France to offset the net investment income tax using the foreign tax credit for taxes that are paid in France. This outcome is different from a previous court case on this same issue. The IRS has appealed the ruling leaving taxpayers in limbo waiting on the final decision regarding the relationship between the net investment income tax and foreign tax credit.

On December 19, 2023, the U.S. Treasury Department announced that the U.S.-Chile Income Tax Treaty is now in force. The treaty provides for reduced withholding tax rates on interest, dividends, and royalties, as well as seeking to eliminate double taxation.

On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (“IRA”), designed to reduce inflation and provide investments in clean energy. The bill has several key provisions, one of which is a new 15% corporate minimum tax on large corporations.