U.S. Court of Appeals for the Federal Circuit
Christensen v. United States
August 31, 2026
Summary
The court held that the U.S.-France tax Convention does not permit the Christensens to use French income taxes as a credit against their U.S. net investment income tax. The Convention's U.S. Law Limitation applies to both Article 24(2)(a) and Article 24(2)(b), making the credits subject to Code provisions that limit foreign tax credits to eligible Chapter 1 taxes. The court therefore reversed the Court of Federal Claims' summary judgment for the Christensens.