Opinion for the court filed by Circuit Judge BUCKLEY.
BUCKLEY, Circuit Judge:
We are asked to determine whether the United States-Canada Income Tax Convention of 1942 permits the United States to tax a Canadian resident's distributable share of capital gain realized by a Massachusetts partnership in which he is a limited partner. On the settled authority of Donroy, Ltd. v. United States,
Let's get started
![Leagle.com](https://www.leagle.com/images/logo.png)
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.