Andersen Managing Director Joe Calianno’s comments are featured in the recent Bloomberg Daily Tax Report article, Expat Tax Credit Rulings Leave Key Treaty Arguments Unresolved. The article focuses on the recent Federal Circuit opinions finding that the foreign tax credit is not allowed against the net investment income tax. Joe questioned whether the court reached the right result given the underlying purpose of tax treaties, which is to alleviate double taxation. These cases highlight a gap between treaty purpose and treaty application: taxpayers can face double taxation even where the treaty is expressly aimed at avoiding it, Joe also noted.