itonewbie
Level 15
01-26-2024
09:11 AM
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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
Still an AllStar