Perspectives

Franco-American successions in both directions: the US heir of a French parent (French duties, Form 3520, basis step-up, inherited funds) and the American citizen dying in France (Form 706, 706-CE credit, non-citizen spouse).

The fifteen-year FATCA record assembled from official audits: the discovery machine that works, the enforcement that ran late, the burden that fell on the compliant, and the window the data describes.

A non-compete payment received after moving abroad remunerates an abstention, and may be taxable in the State of residence, not in France.

The ministerial answer of 2 June 2026 assumes unpaid presidents are not affiliated. On 4 June, the Cour de cassation stated otherwise. What it changes.

The three mechanisms that fire on the executive's departure date: the exit tax with its deferral and discharge, the sourcing split of options and BSPCE after the 2026 reform, and the American entry without step-up.