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Taxation and the Prevention of Fiscal Evasion with Respect to
Taxes on Income and Capital (the 1994 U.S./French Tax
Convention), Aug. 31, 1994, U.S.-France, 2 Tax Treaties (CCH)
par. 3001.19, as modified by applicable subsequent agreements, as
in effect in 2001.
Article 18(2)(a) of the 1994 U.S./French Tax Convention
provides that contributions to a French retirement plan generally
are treated in computing U.S. tax as though they were paid to a
pension or other retirement arrangement established and
recognized for tax purposes in the United States if the competent
authority of the United States agrees that the French pension or
other retirement plan generally corresponds to a pension or other
retirement arrangement recognized for tax purposes by the United
States.
Section 219(a) provides that an individual taxpayer may
deduct qualified retirement contributions made in the taxable
2(...continued)
agrees that a mandatory French pension or other
retirement arrangement generally corresponds to a
United States pension or other retirement arrangement
(without regard to the mandatory nature of such
arrangement), it is understood that contributions to
the French pension or other retirement arrangement
shall be treated in the United States in the same way
for tax purposes as contributions to the United States
pension or other retirement arrangement; and
(iii) a pension or other retirement arrangement is
recognized for tax purposes in a State if the
contributions to the arrangement would qualify for tax
relief in that State.
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Last modified: May 25, 2011