Technical papers
International tax
French Real Estate for Non-Residents: IFI, Inheritance Tax and SCI Structuring
International tax - Published on May 4, 2026
Full analysis of IFI, inheritance tax and tax residence risks for non-residents acquiring French real estate, with practical SCI structuring recommendations.
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US LLC and French Tax: The Carmejane Ruling Changes Everything
International tax - Published on April 27, 2026
The Conseil d'État elevates limited liability to the preponderant classification criterion for US LLCs. Full analysis and practical guidance.
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Foreign Trusts and Foundations: A French Tax Guide for Heirs
International tax - Published on April 13, 2026
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
International tax - Published on April 6, 2026, updated on April 8, 2026
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
International tax - Published on March 23, 2026, updated on April 28, 2026
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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