[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: 26CFR514.110]

[Page 97]
 
                       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. 514.110  Government wages, salaries, and similar compensation, pensions, and life annuities.

    (a) Under Article 8 of the convention, wages, salaries, and similar 
compensation, and pensions paid by France, or by a political subdivision 
thereof, to individuals residing in the United States are exempt from 
Federal income tax. However, under the provisions of Article 14A of the 
convention, such exemption shall not be construed as applying to 
recipients of such income who are citizens of the United States or alien 
residents who are not citizens of France.
    (b) Under the provisions of the same article of the convention 
private pensions and life annuities derived from sources within the 
United States by nonresident alien individuals who are residents of 
France are exempt from Federal income tax. Such items of income are 
therefore not subject to the withholding provisions of the Internal 
Revenue Code. See paragraph IV of the protocol to the convention as to 
what constitutes life annuities. See, also, Sec. 514.109 <SUP>1</SUP> 
with respect to patent and copyright royalties as to the requirements 
necessary to avoid withholding of the tax at the source, which 
requirements are also applicable for the purposes of this section.
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    <SUP>1</SUP> Section 514.109 (formerly Sec. 7.418) was revoked by 
T.D. 6273, 22 F.R. 9529, Nov. 28, 1957.
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