On 13 July 2007, the Advocate General (AG Overgauuw) of the Netherlands Supreme Court delivered his opinion in a case concerning the compensation of losses suffered by a non-resident before the entry into force of the Income Tax Act 2001. (a) Facts. The taxpayer is married and, since 1996, resident in Italy. In 2003, the taxpayer derived only income from savings and investments (Box 3 income) in the Netherlands. Furthermore, the taxpayer in 2003 had loss compensation carryovers in the total amount of EUR 11,675; consisting of an amount of EUR 6,770 which originates from the year 1999 and an...