Business Impact of the United States-France Income Tax Protocol

This Article examines the 1978 Protocol to the France-United States Income Tax Treaty, and examines the operation of those provisions that impact businesses and their employees. The author specifically reviews provisions affecting partnerships, retired persons, investment income, certain fringe benefits, interest, business trips, and shipping and aircraft. The author concludes that, compared to the treaty it modifies, the Protocol does a good job of reducing double taxation, but it does not do the best job.