The U.S. and France signed on January 13, 2009 a protocol updating the current 1994 income tax treaty between the two countries.
The protocol has some significant changes to the current treaty, including, under certain terms, exemption from tax withholding of dividend and cross border royalty payments.
The protocol also rpovides for mandatory arbitration for cases not resolved by the two authorities within a specific period.
It also deals with preventing "treaty shopping", in case of inappropriate use of a tax treaty by third country residents.
For more details please see www.treas.gov.