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Unfortunately I don't think you can actually resolve that problem.
The way I understand the situation with 3D subtitles, you would need the subtitles to specifically be encoded as 3D subtitles for them to work properly in 3D.
And unfortunately, the SBS and OU encoded 3D movies (MKV?) that you are probably playing simply don't come with 3D subtitles. They generally just have flat 2D subtitles that get mangled by the 3D viewing process.
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No i would think it is due to limitations in XBMC that can't handle 3D subtitles. When i want to look at 3D movies with subtitles i switch to MythTV that has support for this. If you have OpenGL rendering in MythTV you can enable 3D support for example SBS. There is not much 3D effect on the subtitles but the appear the right way and it is no problem to read them.