On 3 May 2007, the Luxembourg Administrative Court gave its decision in case No. 22499 C on the taxability of income from real estate derived by a Luxembourg public limited company from real estate held in France through a French partnership, which did not opt to be taxed as a corporate entity in France. Details of the decision are summarized below. (a) Facts. A Luxembourg public limited company (société anonyme, SA)owned all the shares of a French real estate partnership (société civile immobilière, SCI). In 2003 and 2004, the SCI earned rental income from French real estate and realized capital...