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Tax Lawyer, Vol. 61, No. 2 NOTES 639NOteCan a Government Subsidize Itself? Tthe Eerosion of a Bright-Line Rule: PNC Financial Services Group v. CommissionerThe D.C. Circuit’s recent decision in PNC Financial Services Group v. Commisssione ended over 20 years of doubt regarding PNC’s claim to a foreign tax credit arising from a lending transaction with the Brazilian Central Bank.1 In bringing the saga to a close, the D.C. Circuit held that PNC’s foreign tax credit could not simply equal the amount...