HIDE

Client Alerts

French Social Security Charges (C.S.G. and C.R.D.S.) Are Creditable

French Social Security Charges (C.S.G. and C.R.D.S.) Are Creditable

On June 26, the I.R.S. circulated an agency statement providing that the C.S.G. and the C.R.D.S. were not social “taxes” covered by the Totalization Agreement. The I.R.S. thus does not intend to challenge foreign tax credit claims for these two types of French social charges “on the basis that the Agreement on Social Security applies to those taxes.”

Read More

French Social Security Charges (C.S.G. and C.R.D.S.) May Be Creditable

French Social Security Charges (C.S.G. and C.R.D.S.) May Be Creditable

Although the I.R.S. has recognized that foreign social security taxes imposed on net income may constitute creditable taxes for purposes of the Code §901 foreign tax credit provision, French social security charges have been denied such treatment in the past.

Read More