IRS ends challenge to creditability of French CSG and CDRS: EY Tax News Update

June 24, 2019

In documents filed on June 13, 2019 with the U.S. Tax Court in Eshel v. Commissioner (Docket No. 8055-12), which is on remand from the U.S. Court of Appeals for the District of Columbia (D.C. Circuit), the IRS indicated that it will no longer assert that taxpayers are precluded from claiming foreign tax credits for the contribution sociale généralisée (CSG) and the contribution pour le remboursement de la dette sociale (CRDS). As a result, US citizens and resident aliens who pay the CSG and CRDS in France may now claim foreign tax credits to offset their US income tax. Additionally, they potentially may file claims for refund of US income tax by claiming foreign tax credits for CSG and CRDS paid in the last 10 years under Internal Revenue Code Section 6511.

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