Especially in today's economic climate, employers are interested in minimizing the tax cost of executive compensation. France is a relatively high tax jurisdiction.
- We are experts in assessing the tax cost of a given compensation package and in giving suggestions on how this cost can be reduced.
- We draft or otherwise help structure employment agreements, and advise on the most tax-advantaged structure – for employer and employee.
- We look for strategies, such as split compensation agreements, to take advantage of tax treaties and other tax-reducing features in French or U.S. law
- We draft necessary forms and documents to secure protection under the U.S.-France Social Security Treaty, to obtain significant tax savings for both employee and employer during the first 5 years of employment in France.
- We recommend where applicable what specific categories of income may be tax-free or tax-favored in France, including sign-on bonuses, travel hardship allowance or bonus (“prime d’expatriation”). Issues regarding the “prime d’impatriation” are also explored.
- We review and advise on employee stock option plans.
- We review tax equalization or tax reimbursement plans
- We help maximize opportunities for employees who have been dismissed or face dismissal, including the negotiating the severance package itself and the tax treatment thereof.
- The owner-employee. Owner-employees have special needs. Should the entrepreneur become an "employee" of the company? How does the fact that the owner is acting as manager ("gérant" or “PDG”) of his or her company bear on liability issues as well as tax issues? We will guide you through this difficult and unfamiliar terrain.