Treaty Must Be Interpreted to Avoid Double Taxation (1)

A 1994 treaty between the US and France was intended to avoid income being taxed by both countries, and it should be interpreted in that light, two former expatriates told the US Court of Appeals for the Federal Circuit.

Matthew and Katherine Christensen argued that treaty‘s language “should be liberally interpreted” to effectuate its intended purpose: To avoid having to pay taxes for the same income to two countries. Here, they seek to use the treaty to claim a tax credit created by the Affordable Care Act. The broad language of the treaty allows American citizens to pay tax ...