Time is a phenomenon of perspectives.
Jean Cocteau (1889 - 1963)
Perspectives
Italy-Germany-France cross-border gifts: 2026 tax guide
International tax - Published on May 25, 2026, updated on May 27, 2026
How to articulate the Italian D.Lgs. 139/2024 reform, the 1990 France-Italy convention and the German § 21 ErbStG credit to optimise cross-border gifts from Italy.
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French Tax Audit Targeting Algorithm: A Practitioner's Framework
Income tax - Published on May 18, 2026
Technical mapping of the atypia signals exploited by the DGFiP targeting models, reconstructed from publicly available ministerial orders, CNIL deliberations and parliamentary reports.
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Foreign Trusts: Three Major French Tax Decisions from Q1 2026
International tax - Published on May 11, 2026
Analysis of three landmark Q1 2026 decisions reshaping the tax landscape for French-resident trust beneficiaries.
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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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