In 1979, the United States and France revised their 1967 Income Tax Treaty Developed along the lines of the Organization of Economic Co-Op- eration and Development Model Convention, the revised Treaty adopts a unique method of calculating the U.S. foreign tax credit limitation. The re- vised Treaty changed the definition of "source" of income to permit the for- eign tax credit against what would otherwise be termed "U.S. source income. " In this article, Mrs. Simonard examines the revised Treaty and its effects on U.S. citizens residing in France
Stephanie H. Simonard,
Newly Revised Income Tax Treaty with France: A Breakthrough in U.S. Tax Treaty Law,
Nw. J. Int'l L. & Bus.