[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR514.115]

[Page 98]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 514--FRANCE--Table of Contents
 
                       Subpart--General Income Tax
 
Sec. 514.115  Adjustment of tax liability of residents of France and French corporations.

    Article 18 of the convention confers upon the Commissioner authority 
to adjust under the Revenue Act of 1936 the tax liability for taxable 
years beginning prior to January 1, 1936, of nonresident alien residents 
of France, and French corporations, in any case in which such tax 
liability remained unpaid on January 1, 1945. Such provision, however, 
will not apply in any case unless:
    (a) The Commissioner is satisfied that the additional income tax 
involved did not arise by reason of fraud with intent to evade the tax 
on the part of the taxpayer concerned; and
    (b) The taxpayer files, prior to January 1, 1947, with the 
Commissioner a sworn statement showing for each year involved and for 
such other years as the Commissioner may require, (1) by items and 
classes of income the amounts of interest, dividends, rents, salaries, 
wages, premiums, annuities, compensations, remunerations, emoluments, or 
other fixed or determinable annual or periodical income, gains, profits, 
and income derived from sources within the United States; (2) the 
business transactions, if any, carried on in the United States by or in 
behalf of the taxpayer during each of such years; and (3) such further 
information as the Commissioner may require in the particular case.

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