About Income Tax Planning
Income tax planning covers a wide range
of issues and affects most people. When tax laws of more than
one country are involved, expert guidance is indispensable.
Our many years of experience in this challenging field have
given us the expertise to advise on U.S., French and international
tax planning. We use tax treaties, French tax rules and U.S.
tax rules to minimize your French and U.S. income tax and to
avoid double taxation. We specialize in high net worth individuals,
and advise other special categories of taxpayers, such as businessmen,
international executives, retired persons and artists of various
stripes. We advise individuals who surrender their green cards
or their U.S. nationality as to the special U.S. tax rules
affecting them. We also advise U.S. beneficiaries of foreign
trusts.
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Moving to France: Pre-Move Tax Planning
- We help you determine whether and when
you will acquire French tax residence status, and help you
to determine and obtain the visa and resident permit (and
work permit if applicable) appropriate to your situation.
- We explain the French global income
tax system and how the potential for double taxation may
be avoided by U.S. citizens and others who are about to take
up French residence.
- We suggest ways of re-structuring your
investment portfolio and/or structuring your employment agreement
to utilize the tax-saving provisions of the U.S.-France income
tax treaty and other applicable treaties.
- We help you determine whether you have
a continuing State income tax filing obligation after departure
from the U.S.
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Multi-Country Income Tax Issues
- We explain how tax resident status
in France is acquired (and how it may be avoided in some
cases).
- We explain the French tax rules affecting
the "occasional visitor" to France, such as businesspersons,
artistic, scientific and cultural figures, sports figures,
and models.
- We explain how educators teaching in
France for short periods may be sheltered in whole or in
part by tax treaty provisions.
- " We explain how income from sources
outside France is treated in France for tax purposes, and
how double taxation may be avoided.
- We help you to understand the French
wealth tax (ISF) and how to avoid or delay its impact.
- We do tax planning for retired persons
with multi-country sources of income.
- We create corporations in all States
of the U.S. for U.S. citizens or foreign persons and advise
on their use.
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High Net Worth Individuals
- In general, we help the high net worth
individual to understand the impact of the various taxes
impacting on his or her income and wealth and look for ways
to minimize global tax cost.
- " We create scenarios, do calculations
and advise on the best income and asset structure before
you take up French tax residence.
- " We help you to re-structure
your affairs in order to reduce total tax, even after you
have acquired tax residency.
- In the appropriate case, we explore
and identify alternatives to becoming a French tax resident.
- " We advise on the French wealth
tax (ISF). For Americans, we explain how to implement the
5-year tax treaty exemption.
- We analyze U.S. trusts in order to
determine their taxability in France.
- We offer a full range of international
estate planning services.
- We advise on the impact of French "forced
heirship" rules in estate planning.
- We advise on the tax implications of
anticipated legacies or gifts from abroad.
- We work with French Notaires to revise
marital contracts to harmonize the U.S. and French tax results
at death.
- We set up holding company structures
for ownership of French real estate.
- We prepare all relevant income tax
and other tax returns for France and the U.S.
- If you terminating French residency,
we help to regularize your tax situation and obtain appropriate
documentation.
- We assist you in tax inquiries and
tax audits -- French and U.S.
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Planning for the Corporate Executive
- We assess the French and U.S. tax cost
of your compensation package.
- We suggest how local tax law and international
tax treaties can reduce income tax and Social Security tax
cost to employee and employer.
- We explain 5-year exemption from French
Social Security taxes and help secure the exemption when
applicable.
- We set up tax plans for companies to
reduce French income tax paid by the traveling executives.
- We help the owner-employee of a French
corporation deal with special tax and social security issues
applicable to his/her personal status.
- We prepare French and U.S. tax returns
for the executive and review tax equalization calculations.
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Retirement In France
- We help you obtain the appropriate visa
and resident permit.
- " We offer French and U.S. income
tax and estate planning - including wealth tax aspects.
- We advise on the 5-year wealth tax treaty
exemption.
- We analyze your current estate plan to
see how it is affected by the French rules, and advise whether
differences can be harmonized.
- We prepare French and U.S. income tax,
wealth tax and estate or inheritance tax returns.
- We assist in purchasing French real estate,
including interceding with the Notaire and working out a tax-efficient
ownership structure.
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The Professional Artist in France
- We help the professional artist, writer,
musician or dancer, to obtain the appropriate visa and working
papers if necessary.
- We suggest how best to structure legal
presence in France in order to minimize income tax and social
security charges.
- For the occasional visitor, we advise on
any appropriate treaty tax exemptions.
- We advise on special estate planning problems
affecting artists.
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