There is a direct conflict between an Internal Revenue Code section adopted in 2010 and a treaty with France (signed in 2016).The Internal Revenue Code section controls.

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Under the Last-in-Time Rule, if there is a conflict between a provision of a treaty and a later-enacted statute, the statute enacted later in time prevails. Since the treaty with France was signed in 2016, after the adoption of the Internal Revenue Code section in 2010, the provisions of the treaty would control if there is a direct conflict.

There Is a Direct Conflict Between an Internal Revenue Code