Former Treasury Official Backs Taxpayers in US-France Treaty Row

A former international tax counsel for the Treasury Department came out against the government’s interpretation of a US-France treaty, saying US officials risk double taxation by denying a couple their claimed foreign tax credit.

Matthew Christensen and Katherine Kaess Christensen, an American couple living in France, sued the US for denying their claim to a credit toward the net investment income tax imposed by the Affordable Care Act. A trial court agreed with the Christensens that, after paying French tax on capital gains from selling French company shares, the couple is entitled to a credit that offsets their US tax. ...