IRM Interim Guidance: Joint Directive on Creditability of French Social Taxes (IRC §901)

Joint directive to Large Business & International and SBSE examiners, affecting Internal Revenue Manual 4.61.10 that would provide instructions on the creditability of two French social taxes, the “contribution sociale généralisée” (CSG) and the “contribution pour le remboursement de la dette sociale” (CRDS), for U.S. federal income tax purposes, released August 19. The IRS stated that the CSG and CRDS are eligible for a foreign tax credit under tax code Section 901 pursuant to an agreement between the United States and France, and examiners should no longer challenge such foreign tax credit claims. [LB&I-04-0819-007 (Aug. 6, 2019)]

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