Time is a phenomenon of perspectives.
Jean Cocteau (1889 - 1963)
Perspectives
SASU Income Tax: Is Bercy Exposing Its Officials to Concussion?
Positions - Published on October 5, 2026
What a DGFiP official can no longer ignore, what Article 432-10 of the Criminal Code punishes, and why criminal law is not the taxpayer's remedy: a question put to the institution.
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France's 2027 Budget Bill Ends the Apport-Cession Deferral at Death
Positions - Published on October 1, 2026, updated on October 2, 2026
France's 2027 Finance Bill ends the step-up at death for deferred contribution gains. Why the so-called refocus will steer taxpayers away from reinvestment.
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French Assurance-Vie Through American Eyes: PFIC or Grantor Trust?
France-US Tax Desk - Published on September 30, 2026, updated on October 9, 2026
Why the assurance-vie fails the American definition of insurance, the PFIC arithmetic of what it contains, the grantor trust minority thesis, and the four-question triage for existing contracts.
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SASU Income Tax and CSG: Authorities Contradicted by Own Guidance
Income tax - Published on September 28, 2026
Published guidance, the ministerial answer of 2 June 2026 and the genesis of the 2024 reform: three incompatible readings of the SASU president's profit, and three grounds for the reassessed director.
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Delaware, Wyoming or Where You Actually Operate? A Tax Reality Check
France-US Tax Desk - Published on September 25, 2026
What the certificate of incorporation governs, what nexus taxes, when Delaware and Wyoming genuinely earn their reputations, and the three-question grid for the French founder.
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