Tax Court Incorrectly Interpreted U.S.-French Totalization Agreement (Eshel, CA-D.C.), (Aug. 9, 2016)

Tax Court Incorrectly Interpreted U.S.-French Totalization Agreement (Eshel, CA-D.C.), (Aug. 9, 2016)

Reversing and remanding a 2014 decision (Tax Court, 142 TC No. 11, Dec. 59,868), the US Tax Court has determined that taxes, la contribution sociale generalisee (CSG) and la contribution pour le remboursement de la dette sociale (CRDS), paid, in accordance with the terms of a totalization agreement between France and the United States, by […]

Reversing and remanding a 2014 decision (Tax Court, 142 TC No. 11, Dec. 59,868), the US Tax Court has determined that taxes, la contribution sociale generalisee (CSG) and la contribution pour le remboursement de la dette sociale (CRDS), paid, in accordance with the terms of a totalization agreement between France and the United States, by a married couple who worked in France are creditable under Section 317(b)(4) of the Social Security Act.

The CSG and CRDS both amended and supplemented specified laws making up the French social security system under the plain meaning of the terms. Thus, the taxes were covered by the totalization agreement.

Please contact us to find out how the Court’s decision may benefit you.

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