Under new legislation, entitled the Patient Protection and Affordable Care Act (PPACA), high income U.S. citizens living in Canada may pay tax in the U.S. for the first time. The PPACA, part of "ObamaCare," imposes a 3.8% tax on net investment income (NIIT) which includes interest, dividends and capital gains. Although foreign taxes paid by U.S. citizens normally offset taxes owed to the U.S., it is likely, according to U.S. tax lawyer James Gifford, that the PPACA will disallow a credit towards the NIIT for foreign taxes paid.
See ObamaCare Tax Will Hit U.S. Citizens Working Abroad, TaxProf Blog (January 16, 2013).

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