itonewbie
Level 15

I don't think you meant your client resided in France and the USA.  Do you mean your client is a US person (i.e. citizen or GCH) and resided in France?  If he resided in both countries, that would have a different connotation.

You also seem to have misunderstood the treaty and regulation.  What are the treaty article(s) and Treasury Regs you are relying on?

 

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Still an AllStar