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French Supreme Court Rules on Disposal of Interest in a US Partnership by a French Resident, Confirms Exclusive Taxation in France, Denies FTC for US Tax

|Approved Changes|France-United States
France-United States

The French Supreme Court (Conseil d’Etat) on 2 February 2022 issued its decision on a case concerning the tax treatment of capital gains derived by a French resident on the disposal of an interest in a US partnership.

The case concerned a French resident who held a 25% interest in a US partnership treated as a flow-through entity in the US. The taxpayer disposed of his partnership interest in …

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