Form 1116 Foreign Tax Credit (FTC) / US-France Tax Treaty

Forum|Forum|2 years ago
January 26, 2024
1 reply
9 views

I am trying to find the section of the US-France tax treaty where I can the tax rate to be used on Form 1116 to claim the FTC on foreign wages (general category income) are reported on Form 1040. Alternatively, if you know the FTC tax rate for foreign wages, I would appreciate it. Thank you.

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itonewbie

Level 15

Did your client reside in France and render those services in France?

If so, what kind of tax rate are you looking for from the treaty or otherwise?

---------------------------------------------------------------------------------Still an AllStar

M

mtordjmanAuthor

Level 4

Yes, my client resided in France and in the USA. His foreign wages were taxed in France. However, for the purpose of the tax credit to be claimed on Form 1116, the tax treaty tax rate must be used, and not the actual income tax paid in France. This is my understanding of the IRS tax regulations.

itonewbie

Level 15

I don't think you meant your client resided in France and the USA. Do you mean your client is a US person (i.e. citizen or GCH) and resided in France? If he resided in both countries, that would have a different connotation.

You also seem to have misunderstood the treaty and regulation. What are the treaty article(s) and Treasury Regs you are relying on?

---------------------------------------------------------------------------------Still an AllStar

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