One of our guiding principles is to avoid tax audits by adopting appropriate tax return positions. However, audits do occur. We represent our clients before the I.R.S. and the French tax authorities in a tax audit (income tax, wealth tax or estate and gift tax) situation. We negotiate settlements with the tax authorities and attempt to minimize penalties. We file appeals when other possibilities are exhausted. We litigate before the administrative tribunals in the event a tax matter cannot be resolved at the lower levels.
Our international staff has many years of experience in preparing tax returns, including:
- Addressing the essential question of when one may be considered a French tax resident and how one may remain a tax non-resident of France.
- U.S. and French individual income tax returns
- U.S. trust returns
- U.S. corporate income tax and social security returns
- U.S. estate tax returns
- French wealth tax (“ISF”) returns
- French non-resident returns for those with rental real estate in France
- Tax returns for "non-filers", that is, those who are late in their tax filing. We intervene on their behalf to present past year returns and help to avoid or minimize penalties
- Complex tax returns for high net worth individuals
Analysis of tax equalization plans
Review of past year returns to determine whether amended returns are in order to claim refunds based on unclaimed deductions, credits, and the like. As we become familiar with your tax affairs, we are better able to highlight available tax-saving measures you could consider under the French and U.S. tax systems.
Response to queries from the tax authorities. Most queries are benign, but are couched in menacing and often technical language. We are on-call on a year-round basis, to help you respond to those pesky but potentially important missives from the I.R.S. or the French "fisc".