@CalMaple , what I find is this -- there have been some changes made to Dividend taxation -- original article 10 ---- here is the latest-->
" ARTICLE II
Article 10 (Dividends) of the Convention shall be deleted and replaced by the
following:
“Article 10
Dividends
1. Dividends paid by a company that is a resident of a Contracting State to
a resident of the other Contracting State may be taxed in that other State.
2. However, such dividends may also be taxed in the Contracting State of
which the company paying the dividends is a resident and according to the
laws of that State, but if the beneficial owner of the dividends is a resident
of the other Contracting State, the tax so charged shall not exceed:
a) 5 percent of the gross amount of the dividends if the beneficial owner is
a company that owns:
(i) directly at least 10 percent of the voting stock of the company
paying the dividends, if such company is a resident of the United
States; or
(ii) directly or indirectly at least 10 percent of the capital of the
company paying the dividends, if such company is a resident of
France;
b) 15 percent of the gross amount of the dividends in all other cases. "
You can find the treaty and the explanatory notes here -->
France - Tax treaty documents | Internal Revenue Service (irs.gov)
Is there more I can do for you ?
