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|Treaty Development|United States- Luxembourg
United States- Luxembourg

Court of Appeals affirms Guardian Industries case on US foreign tax credit for Luxembourg holding company

The US Court of Appeals for the Federal Circuit has affirmed the decision by the US Court of Federal Claims allowing a US foreign tax credit for Luxembourg taxes paid by a Luxembourg holding company. Guardian Industries Corp. et al. v. United States (Docket No. 2006-5080, 23 February 2007).

The case involved a US corporate group (Guardian Indu…