The Internal Revenue Service (IRS) has recognized in a June 14th court filing that the French Generalized Social Contribution (CSG) and the Contribution for the repayment of social debt (CRDS), are, in fact creditable taxes for US tax purposes. This ends a 7-year legal battle about whether the CSG and the CRDS were “social taxes” …
Eshel v. Comm, 118 AFTR 2d 2016-XXXX (CA Dist Col), 08/05/2016 U..S Court of Appeals for the District of Columbia Circuit In many ways Eshel could be a Treaty Interpretation 101 class. The case focuses on the AGREEMENT ON SOCIAL SECURITY BETWEEN THE UNITED STATES OF AMERICA AND THE FRENCH REPUBLIC (treaty). We need to …
Eshel v. Commissioner: A Refresher in Translating Tax Treaties Read More »
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