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Commentary

6.2.2 US/France tax treaty

France

The US/France tax treaty has significant variations from the OECD model.

US citizens and permanent residents ('green card' holders) are taxable on their worldwide income and gains. However, when they work outside the US for extended periods, they may not be US-resident under the domestic US rules, but will be taxed on all their income in the US (subject to a special deduction for foreign earned

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