Eshel v. Comm'r
United States Tax Court
In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA), Pub.
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In 1987, the United States and France entered into a Totalization Agreement to coordinate benefits under their respective social security systems. Section 317(b)(4) of the Social Security Amendments of 1977 (SSA), Pub. L. No. 95-216, 91 Stat. at 1540, provides that, notwithstanding any other provision of law, taxes paid by an individual to a foreign country "in accordance with the terms of" a totalization agreement shall not be creditable or deductible for Federal income tax purposes. In 2008 and 2009 Ps paid two taxes to the French Government --la contribution sociale généralisée (CSG) and…
1Opinion of the Court
OPINION
Lauber, Judge:
Respondent determined income tax deficiencies of $12,104 and $47,401 for petitioners’ 2008 and 2009 tax years, respectively, and petitioners timely sought redetermination under section 6213.1 The deficiencies stem from disallowance of foreign tax credits that petitioners claimed for payment of certain French taxes. The sole remaining issue for decision is whether two of these taxes— la contribution sociale généralisée (general social contribution or CSG) and la contribution pour le remboursement de la dette sociale (contribution for the repayment of social debt or CRDS) —…
2Cases cited30 opinions
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- Volkswagenwerk Aktiengesellschaft v. SchlunkSupreme Court of the United States · 1988
- Estate of Cowart v. Nicklos Drilling Co.Supreme Court of the United States · 1992
- Medellin v. TexasSupreme Court of the United States · 2008
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3Cited by2 opinions
- Eshel v. Comm'rUnited States Tax Court · 2014
- Ory Eshel & Linda Coryell Eshel v. CommissionerUnited States Tax Court · 2014