On August 5, 2016 the United States Court of Appeals for the District of Columbia Circuits issued it’s decision in the Eshel case.
This important case is here:
FRENCH TAXES US COURT REVERSAL 5 AUG 2016 (1)
Information about the history of the case is here which includes:
A D.C. Circuit panel grilled the Department of Justice’s Tax Division on Tuesday for arguing a foreign tax dispute with dual U.S. and French citizens without first seeking input from the U.S. government, saying the case requires the court to interpret international treaties and examine other policy issues.
The court’s decision, authored by Justice Millet concluded with: