Technical papers

International tax

Foreign Trusts and Foundations: A French Tax Guide for Heirs

How French tax law qualifies and taxes foreign trusts and foundations: inheritance duties, income tax on distributions, and practical guidance for heirs.
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French Tax Residence and Article 6(4) CGI: A Strategic Tool for Cross-Border Couples

How separate taxation under Article 6(4) CGI transforms the fiscal position of internationally mobile households. Case studies and practical guidance.
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US LLC and French Tax: How Courts Decide Between Transparent and Opaque

How French courts classify a US LLC as either a transparent partnership or an opaque corporation under French tax law. Full analysis of seven judicial criteria.
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