Logo
Home Study Material Contact Search
AI Chat FREE
  1. business
  2. accounting
  3. going back to the savary case (tc summary 2010-150

Going back to the Savary case (TC Summary 2010-150) where Savary , a US citizen, was...

50.1K

Verified Solution

Question

Accounting

Going back to the Savary case (TC Summary 2010-150) where Savary, a US citizen, was a flight attendant that lived and worked inParis. The Tax Court reviewing Art 24 (Relief from Double Taxation)in the US-France DTC, concluded that France should give a creditfor the US taxes on Savary's wages. Since France had alreadydeclined to provide a credit for the US tax, Savary was subject todouble taxation by both contracting states on USD 23,321 (the TaxCourt allowed Savary to exclude under sec 911 as foreign earnedincome USD 14,415).

Is this a correct reading of the Art 24? Art 24 has a 3-biterule similar to the 3-bite rule in the US MC. The first bite is Art24(2)(a)(iii). The second bite is Art 24(2)(a). The third bite isArt 24(1)(b)(i). The Treasury Department Technical Explanation tothe US-France DTC provides a clear roadmap to the 3-bite rule soyou may want to read it.

Answer & Explanation Solved by verified expert
4.3 Ratings (701 Votes)
Articule 242aiii states beneficiary shall be entitled to a tax credit against the French tax Such credit shall be equal i in the case of income other than that referred to in subparagraphs ii and iii to the amount of French tax attributable to such income    See Answer
Get Answers to Unlimited Questions

Join us to gain access to millions of questions and expert answers. Enjoy exclusive benefits tailored just for you!

Membership Benefits:
  • Unlimited Question Access with detailed Answers
  • Zin AI - 3 Million Words
  • 10 Dall-E 3 Images
  • 20 Plot Generations
  • Conversation with Dialogue Memory
  • No Ads, Ever!
  • Access to Our Best AI Platform: Flex AI - Your personal assistant for all your inquiries!
Become a Member

Other questions asked by students

Q

16. List the two elements involved in preparing for maintenance on heat exchangers. 21. List two methods...

Mechanical Engineering
Q

Air is supplied to a convergent–divergent nozzle from a large tank in which the pressure and...

Mechanical Engineering
Q

Larger animals have sturdier bones than smaller animals. A mouse's skeleton is only a few...

Physics
Q

Four charges q q q and q are placed at the corner of square of...

Physics
Q

Use the information and table to answer the following question The table shows the results...

Geometry
Q

Find the minimum payment on an unpaid balance of $1,191.74. Assume that the minimum payment...

Basic Math
Q

Imperial Jewelers manufactures and sells a gold bracelet for $408.00. The company's accounting system says...

Accounting
Q

Ayayai Companys record of transactions concerning part X for the month of April was as...

Accounting
Q

Estimated Income Statements, using Absorption and Variable Costing Prior to the first month of operations...

Accounting
Q

Problem IV 22 points Journalize purchase transactions. This information relates to Oscar Golden LLC....

Accounting
Q

A financial manager at Ascot Ltd has gathered the following financial data needed to prepare...

Accounting
Q

Vibrant Company had $1,100,000 of sales in each of Year 1, Year 2, and Year...

Accounting