High Net Worth Individuals
Special Tax Problems
High Net Worth Individuals in France frequently face special tax problems. Our
firm specializes in assisting with:
- Income tax planning, wealth tax planning
and estate planning have special meaning for the high net worth
individuals
- We analyze U.S. trust provisions in order
to determine their taxability in France
- We advise on the tax implications of
anticipated legacies or gifts from abroad
- We help maximize the potential of the
5-year exemption from the French wealth tax (ISF)
- We work with French Notaires to revise
marital contracts so as to harmonize the U.S. and French tax
result at death
- We set up holding company structures
for ownership of French real estate and U.S. real estate
- In general, we help the high net worth
individual to understand the two tax systems and to avoid paying
more tax than is necessary
We help the high net worth individual to
decide whether to become a tax resident of France. The first
order of business is to explain and elucidate how the French
tax system works, how it impacts on compensation, investment
holdings, compensation holdings, pension holdings, real estate
holdings, anticipated gifts and bequests of the individual or
the couple, how it may affect existing or proposed estate plans.
Have you provided in your will for persons outside your immediate
family? How will the French inheritance tax affect those gifts?
Indeed, may any of those gifts be challenged by your children
under the French forced heirship rules? What about generation
skipping trusts, family partnerships, charitable remainder trusts,
and other exotic U.S.-based planning tools that are already part
of your estate plan? Are you engaged in a systematic gift plan
to children? How will that be affected? Do you have asset holdings
in more than one country? How does the French wealth tax apply
to those holdings? We can assist you to understand all of these
vital areas, to identify issues as they pertain to your situation,
and to create tax positions that will focus the matrix of interconnected
issues and, where possible, avoid unwanted results. Pre-move
planning is of course best, but if that is not possible under
the circumstances, post-move re-arrangement of investments, re-casting
of compensation arrangements, modification of testamentary or
trust arrangements, and other permissible actions, some large
and some small, will have a cumulative impact on the bottom line.
It goes without saying that preparation of correct income tax
returns is indispensable to presenting the best possible profile
to the tax authorities, taking tax-saving positions that, while
aggressive in some cases, are defensible in the event of audit.
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