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Can a tax treaty be limited by other provisions in the internal revenue code even if the saving clause does not apply?

Personal Finance & Money Asked by user121664 on October 31, 2021

I am a US resident. In 2019, I had some income from a short employment in Finland. I know I can claim the Foreign Tax Credit, which is equal to the minimum of the taxes I paid to Finland and the taxes I would have paid on that income to the US. Unsurprisingly, the latter of those is smaller, so the Foreign Tax Credit is smaller than the amount I paid in Finnish taxes.

Finland and the US have a tax treaty, which in article 23, paragraph 2 contains:

In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof), the United States shall allow to a resident or citizen of the United States as credit against the United States tax on income

a) the income tax paid to Finland by or on behalf of such resident or citizen;

There is a saving clause in the treaty, but article 23 is excluded. This seems to indicate that I should be able to claim all the income tax paid to Finland as a credit. However I am not sure because of the "subject to the limitations of the law of the United States" part. Does this mean that US law can limit this credit beyond what is indicated in the treaty? Or can I claim an additional credit equal to the difference between the Finnish income tax and the Foreign Tax Credit on Form 8833?

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