Perspectives

The 2026 reform of the French 3% tax and the Sweet Revenge, Satofi, Le Bois Dormant and Sefimo rulings: what foreign owners of French property must check before 15 May 2027.

The France-US estate and gift tax treaty of 1978 read article by article: scope, domicile and the expatriate rule, the allocation of taxing rights and Article 8, three situations where it removes a tax, and its limits since the 2004 protocol.

A position paper: the compliance gap of Americans abroad as an economic problem, what AI changes in the cost of a file, the court sanctions for AI-invented references in the United States and France, and the method of verification and fixed fees that makes augmented practice safe.

Preferential regime, financial assets, transparent entities: the three limits set by France's Conseil d'Etat on Article 123 bis and what they mean for Dubai.

American real estate held by a French resident: rental income and the net basis election, FIRPTA and the French credit on the gain, the estate tax exposure and the pro rata credit of the 1978 treaty, and the choice between direct ownership, LLC and company.