According to recent reports, the French Council of State (Conseil d'État - Supreme Administrative Court) has referred to the French Constitutional Council (Conseil Constitutionnel - Constitutional Court) for a preliminary ruling on whether the inability of taxpayers to carry forward excess tax credits is unconstitutional (for foreign or domestic tax withheld). As provided in the General Tax Code, a tax credit for tax withheld on investment income may generally be used in the year in which the…