A 22 August 2019 judgment of Australia's full Federal Court has been published regarding whether a full foreign tax credit may be claimed in respect of income only partially taxable in Australia. The case involved an Australian trustee of an Australian discretionary trust that held rights to interests in U.S. oil and gas wells. During the years 2010 to 2012, these rights were sold off, and because they were considered U.S. real property interests, the gains were treated as effectively connec…