DC Circ. Chides DOJ For Snub Of US Gov't In French Tax Row

Law360, Washington (October 6, 2015, 4:16 PM EDT) -- A D.C. Circuit panel grilled the Department of Justice's Tax Division on Tuesday for arguing a foreign tax dispute with dual U.S. and French citizens without first seeking input from the U.S. government, saying the case requires the court to interpret international treaties and examine other policy issues.

Brought by Ory and Linda Eshel after claiming they were double taxed by U.S. and French authorities, the lawsuit is hinged on whether two French tax levies the duo paid fall within the 1987 French Totalization Agreement. If so, U.S. social security laws are said to preclude taxpayers from claiming foreign tax credits....

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