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 […]
09/17/2017
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.
Related post
U.S. – Consider filing your 2022 income tax return today if you requested an extension. Don’t unnecessarily wait until October 16, 2023 to file. Here is a summary of what you need to know.
Learn more