Pursuant to an official interpretation by the Department of State in a long-standing case before the US Tax court, the IRS no longer asserts that US income taxpayers living in France are precluded from claiming the foreign tax credits in relation to the French CSG and CRDS, thus withdrawing a position originally posted in 2008 on the website of the US embassy in France and followed by broad audit campaign. This solution is in line with the expert report on French law filed in the interest of the taxpayers. US Tax court n°8055-12 ESHEL / Commisioner of Internal revenue (USA)

- Avis d’expert sur la CSG et la CRDS (expert report)
Download

- U.S. court of appeals for the District of Columbia circuit - August 5, 2016 - No. 14-1215
Download

- Joints status report of 13 June 2019 and Official interpretation by the Department of State of 30 May 2019
Download

- Eshel v. Commissioner: The IRS Concedes Defeat in FTC Case, Tax notes international, 1st July 2019
Download