[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: 26CFR514.114]

[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. 514.114  Credit against United States tax liability for income tax paid to France.

    For the purpose of avoidance of double taxation, Article 14A of the 
convention provides that, on the part of the United States, there shall 
be allowed against the United States income and excess profits tax 
liabilities a credit for any income, war-profits or excess profits taxes 
paid to France by United States citizens or domestic corporations. Such 
principle also applies in the case of a citizen of France residing in 
the United States. Such credit, however, is subject to the limitations 
provided in section 131 of the Internal Revenue Code (relating to the 
credit for foreign taxes) and section 729 of such Code (relating to laws 
applicable). See Secs. 29.131-1 to 29.131-10 of Regulations 111 (26 CFR 
1949 ed. Supps. 29.131-1 to 29.131-10), [Secs. 39.131(a)-1 to 39.131(j)-
1 of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)], and 
Secs. 35.729-1 to 35.729-3 Regulations 112 (26 CFR 1938 ed. Supps. 
35.729-1 to 35.729-3).