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 2002 against an initial payment and complementary payments made until 2008. The taxpayer declared the profits on the disposal in France but claimed a tax credit for US tax on the...