- 4 - reported zero tax liability on her separate Canadian income tax return. Petitioners timely filed a joint U.S. income tax return for 1998 (U.S. return). On their U.S. return, petitioners reported taxable income of $2,099,121 and precredit U.S. tax of $602,237. Petitioners claimed a foreign tax credit of $750,387, based upon the taxes paid by Mr. Price to Canada, and they reported total U.S. tax after this credit of zero. Petitioners also reported alternative minimum tax of zero. Petitioners attached to their U.S. return a Form 6251, Alternative Minimum Tax--Individuals. On their Form 6251, petitioners reported precredit tentative alternative minimum tax pursuant to section 55(b)(1)(A) of $501,999, an alternative minimum tax foreign tax credit of $451,799, and alternative minimum tax of $50,200. At the top of Form 6251 appear the handwritten words "Treaty Override see [Form] 8833". Petitioners also attached to their U.S. return two Forms 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b). On one of the Forms 8833, petitioners asserted that section 59 is overruled or modified by article XXIV of the U.S.-Canada treaty. They set forth the following explanation of their position:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011