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Russian Scientist’s Tax Exemption Treaty Case Merits Closer Look

April 7, 2022, 4:52 PM

The U.S. Tax Court misunderstood the basis of a U.S.-Russia Tax Treaty distinction when it held that payments to a Russian scientist working in the U.S. were tax-exempt, an appeals court ruled.

The Wednesday decision from the U.S. Court of Appeals for the Fourth Circuit sent the case back to the Tax Court for further factual findings to determine whether payments to Russian physicist Vitaly Baturin for his work at a particle accelerator lab in Virginia qualified for the treaty’s tax exemption.

The three-judge appeals panel specifically rejected the Tax Court’s 2019 conclusion that ...