Perspectives

The American expatriation regime seen from France: who is a covered expatriate, the three tests and 2026 thresholds, the deemed sale and special regimes, the 40% tax on American heirs since 2025, the French non-recognition of the exit tax and the ten-year treaty clause.

Home, centre of economic interests, foreign certificates: what French appeal courts held in 2026 and how to plan a tax-defensible departure from France.

Repatriation between a US subsidiary and its French parent company: treaty withholding rates and the zero rate, limitation on benefits, the French parent-subsidiary regime and the lost withholding, intercompany interest and royalties, return of capital and the branch alternative.

The French company’s first American hire decoded: the three employer architectures, the real cost of payroll and benefits, the seconded employee, and when the hire creates a permanent establishment.

One distribution from a foreign trust or foundation now brings all its real estate assets into the French IFI. What this means ahead of the 2027 disclosure facility.